Mueller v. Commissioner of Internal Revenue Service

MEMORANDUM OPINION ■

HIGHSMITH, District Judge.

THIS CAUSE is before the Court for judicial review of a jeopardy assessment made by the Internal Revenue Service (“IRS”) against Plaintiffs Christa Karin Mueller and Rein-*1061hard Mueller, for the 1986 tax year. In lieu of an evidentiary hearing, the Court required the parties to submit evidence relative to their respective burdens in this proceeding. Upon review of the submissions and the record, the Court makes the following findings and conclusions.

EVIDENTIARY FINDINGS

On June 23, 1994, a grand jury for the United States District Court for the…