United States v. Vicknair

ORDER APPROVING JEOPARDY ASSESSMENT

JAMES LAWRENCE KING, District Judge.

This cause comes before the court in the form of an action for the early determination of the reasonableness and appropriateness of an Internal Revenue Service Jeopardy Assessment pursuant to 26 U.S.C. § 7429(b). 1

In this jeopardy assessment proceeding, this court must determine whether the decision of the Internal Revenue Service to levy an assessment against the taxpayer Vicknair for the calendar years 1975 and 1976 was reasonable. This determination is to be made on the basis of facts known to the Service at the time…