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WELLEK v. U.S.

No. 04 C 3453.

324 F.Supp.2d 905 (2004)

Michael G. WELLEK, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Illinois, Eastern Division.

July 7, 2004.

Attorney(s) appearing for the Case

Harvey M. Silets, Gil M. Soffer, Jenny Louise Johnson, Katten Muchin Zavis Rosenman, Chicago, IL, for Plaintiff.

AUSA, Samuel D Brooks, United States Attorney's Office, Chicago, IL, David M. Steiner, Glenn J. Melcher, United States Department of Justice, Washington, DC, for Defendant.

MEMORANDUM OPINION AND ORDER

ST. EVE, District Judge.

In April 2004, the Internal Revenue Service ("IRS") issued a jeopardy assessment and jeopardy levy upon approximately $12,000,000 of Plaintiff's seized cash to satisfy past due tax obligations totaling $11,537,250.16. Plaintiff filed a complaint pursuant to 26 U.S.C. § 7429(b) seeking a judicial determination of the reasonableness of the jeopardy assessment, jeopardy levy, and the amount assessed...

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