Felkel v. United States

HAMILTON, District Judge.

FINDINGS OF FACTS AND CONCLUSIONS OF LAW

This Court, having considered the facts and evidence produced at the hearing of this matter, the briefs and submissions of the parties, the arguments of counsel, and being otherwise fully advised in the premises, hereby enters the following Findings of Facts and Conclusions of Law.

FINDINGS OF FACT

1. After review of the recommendation for jeopardy assessments made by Revenue Agent Diana Acuff and approval at the intermediate levels of authority, the District Director of Internal Revenue personally approved the making of the…