Selbe v. United States

MEMORANDUM OPINION

KISER, Chief Judge.

On April 2, 1992, the Internal Revenue Service (“IRS”) made a jeopardy assessment against the plaintiff, Frank G. Selbe III, for unpaid federal income tax from the years 1983 and 1984, under 26 U.S.C. § 6861. Sel-be sought administrative review and was denied relief. He then filed the instant action seeking a judicial determination regarding the reasonableness of the jeopardy assessment and the amount assessed, under 26 U.S.C. § 7429. Jurisdiction is proper under that section. The parties are now before me on Selbe’s motion for summary judgment, filed pro…