McAvoy v. Internal Revenue Service

OPINION AND ORDER

MILES, District Judge.

This cause comes before the Court in the form of an action for summary review of a termination assessment made against plaintiff on February 14, 1979. The termination assessment was made pursuant to 26 U.S.C. § 6851 and was in the amount of $107,908 for the taxable year of 1978 and $3,485 for the taxable year of 1979. At plaintiff’s request, the Secretary of the Treasury has reviewed the reasonableness of the assessment in accordance with 26 U.S.C. § 7429(a), and affirmed the District Director. Plaintiff now seeks judicial review of the termination…