Guillaume v. Commissioner

MEMORANDUM OPINION

MARTINEZ, District Judge.

THIS CAUSE came before the Court upon Claude Guillaume’s Petition for Determination and Review of Notice of Termination Assessment and Jeopardy Levy (D.E. No. 1). For the reasons set forth below, the Court finds the termination assessment is reasonable and the amount assessed is appropriate under the circumstances of this case.

I. Background

On March 2, 2001, Petitioner Claude Guillaume was arrested on charges of trafficking in cocaine (Joint Pretrial Stipulation [“JPTS”], Docket Entry Number [“D.E. No.”] 42 at ¶ V(l)). 1 Law enforcement officials…