Felix B. Vicknair and Fbv Corporation, Individually, and as Nominee for Felix B. Vicknair v. United States

POLITZ, Circuit Judge:

Appellants Felix B. Vicknair and FBV Corporation were served with jeopardy assessments pursuant to 26 U.S.C. § 6861 1 for the tax years 1975 and 1976, in the total sum of $313,686.38. They sought administrative review of the assessments in accordance with the provisions of 26 U.S.C. § 7429. 2 When the assessments were up held they sought judicial review as prescribed by § 7429. The district court, 452 F.Supp. 470, found the jeopardy assessments reasonable and approved their imposition. These appeals follow. We dismiss the appeals.

Jeopardy assessments, as sanctioned by §…