Perlowin v. Sassi

MEMORANDUM AND ORDER

PECKHAM, Chief Judge.

Plaintiff moves for summary judgment on the question of the validity of a termination assessment made by defendant District Director of the Internal Revenue Service (“the Service”) in connection with plaintiff’s 1980 taxes. Plaintiff seeks a declaration that the termination assessment is in valid; an injunction restraining defendants from any further collection proceedings relating to the termination assessment; and an order requiring defendants to return to plaintiff all assets seized and held pursuant to the termination assessment. Defendants have…