Fidelity Equipment Leasing Corp. v. United States

NATURE OF THE PROCEEDINGS

HAROLD L. MURPHY, District Judge.

On October 23,1978, the plaintiffs filed a complaint to determine the reasonableness and appropriateness of two jeopardy assessments for income tax levied against them by the Internal Revenue Service on August 9, 1978. Jurisdiction of the Court was invoked pursuant to 26 U.S.C. § 7429(b).

These jeopardy assessments were made by the District Director of the Internal Revenue Service pursuant to Section 6861 of the Internal Revenue Code, 26 U.S.C. § 6861, which states in part:

If the Secretary or his delegate believes that the assessment or…