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WALKER v. UNITED STATES

Nos. Civ. 3-86-480, Civ. 3-86-481.

650 F.Supp. 877 (1987)

Don E. WALKER, Plaintiff, v. UNITED STATES of America, Defendant. (Two Cases)

United States District Court, E.D. Tennessee, N.D.

January 5, 1987.

Attorney(s) appearing for the Case

Ralph E. Harwell, Randall E. Nichols, Knoxville, Tenn., for plaintiff.

John W. Gill, U.S. Atty., Knoxville, Tenn., Paul M. Predmore, Asst. U.S. Atty., Dept. of Justice, Tax Div., Washington, D.C., for defendant.

MEMORANDUM

JARVIS, District Judge.

These are consolidated actions in which plaintiff taxpayer seeks judicial review to determine the reasonableness and appropriateness of two jeopardy assessments, one under § 6861 of the Internal Revenue Code of 1954 (26 U.S.C.) [the "Code"] for unpaid income taxes for 1982, 1983 and 1984 and the other under § 6862 of the Code for unpaid excise taxes for 1984 and 1985. Jurisdiction is invoked pursuant to...

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