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VANERIO v. I.R.S.

No. 85 CV 3921.

629 F.Supp. 1141 (1986)

Delfo VANERIO and Marlene Vanerio, Plaintiffs, v. INTERNAL REVENUE SERVICE, Defendant.

United States District Court, E.D. New York.

March 10, 1986.

Attorney(s) appearing for the Case

Pappas & Russo, Bellmore, N.Y. (Richard Reers, Vincent Russo, Stewart D. Weinreb, of counsel), for plaintiffs.

U.S. Dept. of Justice, Tax Div., Washington, D.C., Kenneth C. Brown, of counsel, for defendant.

MEMORANDUM AND ORDER

McLAUGHLIN, District Judge.

This is an action for judicial review of "termination assessments" of federal income tax liability made against the plaintiff pursuant to 26 U.S.C. § 6851. For the reasons stated below, the assessments are upheld.

Facts

The termination assessments made by the Internal Revenue Service ("IRS") against the taxpayers resulted from a criminal investigation, the pertinent facts of which...

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