Rey Balaguer v. United States

OPINION AND ORDER

GIERBOLINI, District Judge.

Plaintiff brought this action under 26 U.S.C. § 7429(b), to review a jeopardy assessment and termination notice sent to him by the Internal Revenue Service (IRS). On June 21, 1985, the IRS notified plaintiff that it was performing a jeopardy assessment of his tax liability and terminating the taxable year of 1985. The IRS* had concluded that plaintiff appeared to be quickly placing his property beyond the reach of the government by concealing, dissipating, or transferring it to other persons. As a result, the IRS assessed on plaintiff a tax…