Vanerio v. Internal Revenue Service

MEMORANDUM AND ORDER

McLAUGHLIN, District Judge.

This is an action for judicial review of “termination assessments” of federal income tax liability made against the plaintiffs pursuant to 26 U.S.C. § 6851. For the reasons stated below, the assessments are upheld.

Facts

The termination assessments made by the Internal Revenue Service (“IRS”) against the taxpayers resulted from a criminal investigation, the pertinent facts of which are as follows:

Prior to July 26, 1985, Detective James Perretto of the New York Drug Enforcement Task Force was notified by a confidential informant that certain…