United States v. Doyle

DECISION AND ORDER

REYNOLDS, Chief Judge.

This is an action brought by the United States to reduce a federal tax assessment against LeRoy Doyle (“taxpayer”) to judgment and to enforce a corresponding federal tax lien against certain property owned by the taxpayer. The taxpayer has counterclaimed for a determination of the reasonableness of the assessment pursuant to the statutory procedure set out in 26 U.S.C. § 7429. Currently before the court are the taxpayer’s motion for summary judgment and the Government’s motion for summary determination of the reasonableness of the assessment and its…