Settipane v. United States

Findings of Fact and Conclusions of Law

KEETON, Senior District Judge.

This matter came before the court for judicial review of a jeopardy assessment made by the Internal Revenue Service (“IRS”) against the Plaintiff, Richard Set-tipane, II (“Plaintiff’), for the tax years 1997 through 2002. The court held a bench trial. Upon full hearing and consideration of this matter the court reaches the following Findings of Fact and Conclusions of Law:

FINDINGS OF FACT:

1. Plaintiff resides at 16 Sunset Avenue, North Reading, Massachusetts 01864 (“the Property”). (Govt. Exhibit 1 at p. 1; Testimony of Leca…