Johnson v. Commissioner

FINDINGS OF FACT AND CONCLUSIONS OF LAW

MELTON, District Judge.

This cause is before the Court on a complaint filed on February 23, 1979, to determine the reasonableness and appropriateness of a jeopardy assessment imposed upon the plaintiffs by the Internal Revenue Service (hereinafter “the Service”) on December 20,1978. See 26 U.S.C. § 7429(b) (1976). The Service imposed the jeopardy assessment for two reasons: first, because it appeared that the plaintiffs’ continued solvency was questionable; and second, because it appeared that the plaintiffs had undertaken to conceal certain of their…