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MILLER v. UNITED STATES

No. C 85-7412.

615 F.Supp. 781 (1985)

David J. MILLER, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Ohio, W.D.

June 13, 1985.

Attorney(s) appearing for the Case

Richard S. Lynch, Norwalk, Ohio, for plaintiff.

Thomas Jones, U.S. Dept. of Justice, Tax Div., Northern Region, Washington, D.C., for defendant.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

JOHN W. POTTER, District Judge:

This cause came to be heard upon plaintiff's complaint to review defendant's jeopardy assessment made against plaintiff. This action is brought under federal statutory law. Plaintiff predicates jurisdiction upon 28 U.S.C. § 1340 and 26 U.S.C. § 7429.

Plaintiff asserts that the United States Internal Revenue Service (hereafter Service) made a jeopardy assessment in the...

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