Varjabedian v. United States

FINDINGS OF FACT AND RULINGS OF LAW AFTER BENCH TRIAL ON PLAINTIFF’S CHALLENGE TO JEOPARDY ASSESSMENT

DEIN, United States Magistrate Judge

I. INTRODUCTION

Plaintiff, Edward Paul Varjabedian (“Varjabedian”), filed this action pursuant to 26 U.S.C. § 7429(b) seeking judicial review of a jeopardy assessment conducted by the Internal Revenue Service (the “IRS” or “government”) in December, 2002 for the income tax years 1997-2000 and the employment tax years 1999-2001. Varjabedian challenges both the IRS’ decision to initiate the jeopardy proceeding in the first place as well as the amount assessed…