MUELLER v. C.I.R.

No. 95-6078-CIV.

882 F.Supp. 1060 (1995)

Christa Karin MUELLER and Reinhard Mueller, Plaintiffs, v. COMMISSIONER OF INTERNAL REVENUE SERVICE and United States of America, Defendants.

United States District Court, S.D. Florida.

February 21, 1995.


Attorney(s) appearing for the Case

Jose Francisco De Leon, U.S. Dept. of Justice, Tax Div., Washington, DC, for defendants.

Martin Press, Broad & Cassel, Ft. Lauderdale, FL, for plaintiffs.


MEMORANDUM OPINION

HIGHSMITH, District Judge.

THIS CAUSE is before the Court for judicial review of a jeopardy assessment made by the Internal Revenue Service ("IRS") against Plaintiffs Christa Karin Mueller and Reinhard Mueller, for the 1986 tax year. In lieu of an evidentiary hearing, the Court required the parties to submit evidence relative to their respective burdens in this proceeding. Upon review...

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