DeLauri v. United States

MEMORANDUM OPINION AND ORDER

HUDSPETH, District Judge.

This action was filed by Plaintiffs, Patrick DeLauri and Del Enterprises, Inc., seeking judicial review pursuant to 26 U.S.C. § 7429(b) of jeopardy assessments for income tax levied against them by the Internal Revenue Service (IRS) on March 3, 1980.

The jeopardy assessments were made pursuant to 26 U.S.C. § 6861(a), which provides for immediate assessment of tax deficiencies if the IRS believes that collection of such deficiencies will be jeopardized by delay. Letters were mailed to Plaintiffs on March 3, 1980, notifying them of the amounts…