Nolan v. United States

ORDER

MARY ANNE RICHEY, District Judge.

Having heard the evidence presented at the judicial review proceeding December 2, 1981, and having considered all memoranda of law, the Court rules as follows:

Jeopardy and termination assessments against plaintiff-taxpayer are found to be reasonable, but the amount of the assessment is found to be inappropriate due to substantial doubts raised by plaintiff in regard to estimated amounts of income. Therefore, the Court remands the complaint to the Secretary of the Treasury for redetermination of the amount of income on which the assessments are based…