Mesher v. United States

OPINION

FRYE, District Judge:

Plaintiff, Brent J. Mesher, commenced this action pursuant to 26 U.S.C. § 7429 to obtain summary review of a jeopardy assessment made against him for unpaid federal income taxes and the penalties thereon for the tax years 1981 through 1988 in the aggregate total amount of $1,105,371.00. The government moves for summary judgment (# 16) on the grounds that no genuine issue of material fact remains with regard to the reasonableness of the jeopardy assessment made against Mesher and the appropriateness of the amount of the jeopardy assessment. Mesher has cross-moved…