LINDHOLM v. U.S.

Civ. A. No. 92-2136.

808 F.Supp. 1 (1992)

Magnus LINDHOLM, Plaintiff, v. UNITED STATES of America, et al., Defendants.

United States District Court, District of Columbia.

September 28, 1992.


Attorney(s) appearing for the Case

Jay Stephens, U.S. Atty., Margaret M. Earnest, Tax Div., Dept. of Justice, Washington, DC, for U.S.

J. Roger Mentz, Linda E. Carlisle, McClure, Trotter & Mentz, Washington, DC.

Michael Quigley, Lucy W. Plisken, Akin, Gump, Hauer & Feld, Washington, DC.


MEMORANDUM OPINION

REVERCOMB, District Judge.

On June 1, 1992, the Internal Revenue Service (IRS) made a jeopardy assessment against the plaintiff pursuant to 26 U.S.C. § 6861. On September 18, 1992, the plaintiff filed this action under 26 U.S.C. § 7429(b), which provides for expedited judicial review of jeopardy assessments. The Court's task in reviewing a jeopardy assessment is to determine whether "the making of the assessment ... is reasonable...

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