MEMORANDUM AND ORDER
HARRINGTON, District Judge.
Procedure
This case comes before the Court as a suit arising under the laws of the Internal Revenue Code, 26 U.S.C. §§ 6851, 6867 and 7429. The plaintiff, Carl N. Lavnikevich, seeks this Court's review of a tax assessment in the amount of $75,282 in cash by the Internal Revenue Service ("I.R.S."). Plaintiff claims this tax was erroneously and illegally assessed against and collected...
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