Saki International, Inc. v. United States

ORDER

DOWD, District Judge.

This action was brought by the plaintiff taxpayer as an action for judicial review of a jeopardy assessment made by the IRS against the plaintiff's property. Such an action is governed by a specialized statutory procedure found at 26 U.S.C. § 7429(b). In the ordinary case the district court must determine two things:

1. whether the making of the assessment is reasonable under the circumstances, and

2. whether the amount assessed is appropriate under the circumstances.

Unless the Court acts outside of its authority under this special statutory provision, as opposed to…