Harper v. United States

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER

MELTON, Senior District Judge.

This cause is before the Court upon plaintiff Margie Reed Harper’s (“Harper”) request under 26 U.S.C. § 7429 (1988) for judicial review of an April, 1990, transferee jeopardy assessment made against her by the Internal Revenue Service (“IRS”) for unpaid federal income taxes of her former husband Rodney W. Reed. The Court conducted an evidentiary hearing on December 12, 1990, at which time both parties presented evidence and examined witnesses. The parties submitted proposed findings of fact and conclusions of law to…