Hatfield v. United States

*1379ORDER

O’KELLEY, Chief Judge.

This is an action for judicial review of the “termination assessment” of federal income tax made against the petitioner pursuant to 26 U.S.C. §§ 6851 and 7429. This action was commenced on November 6, 1987. Pursuant to § 7429(b)(2), a district court has twenty days from the date the action is commenced to make its determination. The taxpayer in this case, however, made a request for an extension, in which the government concurred. The court by order of November 23, 1987 granted the parties an additional forty day extension. On December 21, 1987, the court held a…