Camp v. Commissioner

*586ORDER AND REASONS

FELDMAN, District Judge.

At issue before the Court is the question of whether a jeopardy assessment made by the Internal Revenue Service should be set aside.1

On January 30, 1986 a jeopardy assessment for income tax deficiencies in the amount of $29,478,718.00 was made against Adler B. Seal, regarding tax deficiencies allegedly due for the taxable years 1981, 1982 and 1983.2

Before his death, Mr. Seal was extensively involved in smuggling illicit and illegal drugs into the United States. He was a criminal character. He was the subject of two convictions in federal courts in…