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KENNEY v. UNITED STATES

Civ. No. 85-0142 P.

622 F.Supp. 219 (1985)

Edward Patrick KENNEY [Taxpayer], Petitioner, v. UNITED STATES of America, [Internal Revenue Service], Defendant.

United States District Court, D.C. Maine.

November 15, 1985.

Attorney(s) appearing for the Case

Judy Potter, University of Southern Maine Law School, Portland, Me., for petitioner.

Richard S. Cohen, U.S. Atty., Joseph H. Groff, III, Asst. U.S. Atty., Portland, Me., Thomas R. Jones, Asst. U.S. Atty., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

ORDER DENYING IN PART AND GRANTING IN PART TAXPAYER'S PETITION FOR JUDICIAL REVIEW OF JEOPARDY ASSESSMENT

GENE CARTER, District Judge.

Petitioner, Taxpayer Edward Patrick Kenney seeks review of a jeopardy assessment made against him by the Internal Revenue Service pursuant to 26 U.S.C. § 6861(a) (1983). In reviewing a jeopardy assessment, this Court is required to determine (1) whether the making of an assessment is reasonable under the circumstances...

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