Steiner v. Reisimer

GRUBB, District Judge.

Plaintiffs brought this action to enjoin, the defendant from assessing or collecting additional taxes for three specified years until the expiration of the 90-day period after notice of a determination of deficiency is properly mailed to the plaintiffs. The plaintiffs further prayed that, certain levies heretofore made by the defendant be declared null and void.

The complaint alleged that in a dispute over tax liability the Internal Revenue Service prepared Forms 870M, entitled “Waiver of Restrictions on Assessment and Collection of Deficiency in Tax”, for the signature…