Walker v. United States

MEMORANDUM

JARVIS, District Judge.

These are consolidated actions in which plaintiff taxpayer seeks judicial review to determine the reasonableness and appropriateness of two jeopardy assessments, one under § 6861 of the Internal Revenue Code of 1954 (26 U.S.C.) [the “Code”] for unpaid income taxes for 1982, 1983 and 1984 and the other under § 6862 of the Code for unpaid excise taxes for 1984 and 1985. Jurisdiction is invoked pursuant to § 7429(b) of the Code and is not in dispute.

In particular, these jeopardy assessments were made by the District Director [“Director”] of the Internal Revenue…