Pinto v. United States

MEMORANDUM AND ORDER

SAFFELS, District Judge.

This is a summary proceeding pursuant to 26 U.S.C. § 7429(b) to review jeopardy assessment procedures taken by the Internal Revenue Service (hereinafter IRS) against the plaintiff arising from alleged tax deficiencies for the years 1977 through 1979.

The statute provides an expedited procedure whereby a taxpayer may have a United States District Court determine the reasonableness of a jeopardy assessment and the reasonableness of the amount assessed. The procedure is summary, and final disposition on the merits may be made through other methods. In…