United States v. Maxwell

ROBERT M. HILL, District Judge.

MEMORANDUM OPINION

This is a civil action brought by the United States to reduce to judgment tax assessments in the amount of $313,631.45 against John H. and Vera R. Maxwell.

I. FACTS

On March 24, 1959, a jeopardy assessment was entered against both the Max-wells pursuant to 26 U.S.C. § 6861 for the major portion of the taxes involved in this action.1

On August 3, 1959, the taxpayers appealed the assessment to the Tax Court of the United States. The Tax Court rendered its decision in favor of the United States on December 30, 1964. John H. Maxwell and Vera R.…