ORDER
REGGIE B. WALTON, United States District Judge
The plaintiff, Gerd Topsnik, has filed this action against the United States seeking review under 26 U.S.C. § 7429 (2012) of a jeopardy assessment and levy imposed upon him by the Internal Revenue Service ("IRS"). Complaint ("Compl.") ¶ 1. Currently before the Court are the United States' Motion for Summary Determination ("Gov't's Mot.") and...
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