Stebco, Inc. v. United States

ORDER DENYING DEFENDANT’S MOTION TO DISMISS; GRANTING PLAINTIFFS’ MOTION FOR ABATEMENT OF JEOPARDY ASSESSMENT

RHOADES, District Judge.

BACKGROUND

On February 2, 1990, plaintiffs filed a complaint to determine the reasonableness and appropriateness of two jeopardy assessments levied against them by the Internal Revenue Service (“IRS”). The jeopardy assessment made by the IRS against Stebco, Inc. (“Stebco”) and the individual taxpayers resulted from an IRS investigation. 1 The IRS gathered the following information, which was presented to the court by way of declaration of a Revenue Agent, Beatriz…