MEMORANDUM OPINION AND ORDER
HUDSPETH, District Judge.
On June 25 and June 28, 1984, the Internal Revenue Service, acting pursuant to the authority of 26 U.S.C. § 6851, terminated the 1984 tax year of Mardoqueo M. Alfaro, and assessed income taxes totaling $28,341,706.00. In the form of a cross-claim in an interpleader action, Alfaro seeks to challenge pursuant to 26 U.S.C. § 7429 both the reasonableness of the termination assessment and the appropriateness...
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