Central De Gas De Chihuahua, S.A. v. United States

MEMORANDUM OPINION AND ORDER

RUESCH, United States Magistrate Judge.

Plaintiffs filed these three cases seeking judicial review, under 26 U.S.C. § 7429(b), of jeopardy assessments imposed by the Internal Revenue Service (IRS). The parties consented to Magistrate Judge jurisdiction under 28 U.S.C. § 686(c) and requested consolidation of the evidentiary hearings. The consolidated evidentiary hearings were held on April 16 and 17, 1992. Plaintiffs were represented by George W. Connelly of Houston, Texas and the Government was represented by Mary C. Vance, an attorney in the Tax Division of the…