MEMORANDUM AND ORDER
JOSEPH C. HOWARD, District Judge.
On March 29, 1985, the District Director of Internal Revenue for Baltimore made jeopardy assessments (26 U.S.C. § 6861) against Helene Klotzman as transferee of Richard Klotzman; Helene Klotzman, trustee for Heidi Klotzman, as transferee of Richard Klotzman; and, Richard Klotzman and Helene Klotzman, tenants by the entireties, as transferees of Richard Klotzman, in the amounts of $125,196, $125...
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