MEMORANDUM OPINION AND ORDER
RUESCH, United States Magistrate Judge.
Plaintiffs filed these three cases seeking judicial review, under 26 U.S.C. § 7429(b), of jeopardy assessments imposed by the Internal Revenue Service (IRS). The parties consented to Magistrate Judge jurisdiction under 28 U.S.C. § 636(c) and requested consolidation of the evidentiary hearings. The consolidated evidentiary hearings were held on April 16 and 17, 1992. Plaintiffs...
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