Legal Opinion
Lindholm v. United States
District Court, District of Columbia
Decided September 28, 1992No. Civ. A. 92-2136PublishedCited by 5 opinions
1Opinion of the Court
MEMORANDUM OPINION
REVERCOMB, District Judge.
On June 1, 1992, the Internal Revenue Service (IRS) made a jeopardy assessment against the plaintiff pursuant to 26 U.S.C. § 6861. On September 18, 1992, the plaintiff filed this action under 26 U.S.C. § 7429(b), which provides for expedited judicial review of jeopardy assessments. The Court’s task in reviewing a jeopardy assessment is to determine whether “the making of the assessment ... is reasonable under the circumstances,” and whether “the amount so assessed ... is appropriate.” § 7429(b)(3)(A). The Court has twenty days from the filing of…
2Cases cited5 opinions
- Commissioner v. ShapiroSupreme Court of the United States · 1976
- Haskin v. United StatesDistrict Court, C.D. California · 1977
- McAvoy v. Internal Revenue ServiceDistrict Court, W.D. Michigan · 1979
- Hohman v. United StatesDistrict Court, District of Columbia · 1982
- George F. Harding Museum v. United StatesDistrict Court, N.D. Illinois · 1987
3Cited by5 opinions
- Friko Corporation, Johnny Daccarett-Ghia, as Alleged Alter Ego or Nominee of Friko Corporation v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1994
- Granse v. United StatesDistrict Court, D. Minnesota · 1995
- Topsnik v. United StatesDistrict Court, District of Columbia · 2013
- Mueller v. Commissioner of Internal Revenue ServiceDistrict Court, S.D. Florida · 1995
- Simpson v. Great Socialist People's Libyan Arab JamahiriyaDistrict Court, District of Columbia · 2013