Klotzman v. United States, Internal Revenue Service

MEMORANDUM AND ORDER

JOSEPH C. HOWARD, District Judge.

On March 29, 1985, the District Director of Internal Revenue for Baltimore made jeopardy assessments (26 U.S.C. § 6861) against Helene Klotzman as transferee of Richard Klotzman; Helene Klotzman, trustee for Heidi Klotzman, as transferee of Richard Klotzman; and, Richard Klotzman and Helene Klotzman, tenants by the entireties, as transferees of Richard Klotzman, in the amounts of $125,196, $125,000, and $179,452, respectively. Mrs. Klotzman administratively appealed the Director’s decision and lost. 26 U.S.C. § 7429(a). She now seeks…