Linda Marie Nichols v. United States

WATERS, District Judge:

On January 18, 1978, the Internal Revenue Service made a termination assessment pursuant to 26 U.S.C. § 6851 against appellant, Linda Marie Nichols. The termination assessment was for the 1977 tax year and totaled $177,484.80. The assessment was satisfied from funds that had been seized by the Federal Drug Enforcement Agency in July of 1977.

Appellant requested administrative review of the assessment pursuant to 26 U.S.C. § 7429(a)(2). Since the administrative process was not resolved, appellant filed a complaint in the district court pursuant to 26 U.S.C. § 7429(b). The…