Harry E. Hall v. Commissioner, Internal Revenue Service (Department of Treasury)
Court of Appeals for the Eleventh Circuit
1Opinion of the Court
CORRECTED OPINION
GODBOLD, Circuit Judge:
Hall appeals from the district court’s dismissal of his suit seeking review pursuant to 26 U.S.C. § 7429 of termination and jeopardy assessment against him with respect to income taxes for the year 1984 and a § 6700 penalty for allegedly promoting “abusive” tax shelters.
On June 10, 1985 Hall filed an action pursuant to 26 U.S.C. § 7429 seeking a determination of the validity of the I.R.S. Commissioner’s termination and jeopardy assessments, but he failed to submit a motion for rule nisi along with his complaint as required by Local Rule 325-1 of N.D.…
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