Golden ADA, Inc. v. United States

MEMORANDUM AND ORDER

THELTON E. HENDERSON, Chief Judge.

INTRODUCTION

On December 22,1995, the court heard the petition of plaintiffs Golden ADA, Inc. and its subsidiaries1 (“Golden ADA”) for a determination of the reasonableness of a jeopardy assessment levied against it by the Internal Revenue Service (“IRS”) on November 7, 1995. The IRS based its jeopardy assessment on information it gathered as a result of an ongoing investigation into plaintiffs’ import/export of rough and polished diamonds as well as gold and other precious gemstones from the former Soviet Republic. The IRS relied in large…