PARKINSON, Circuit Judge.
This appeal was taken by the defendant below, the District Director of Internal Revenue, from an order of the District Court preliminarily enjoining the enforcement of a jeopardy assessment against plaintiffs for the taxable year 1956. The order, entered July 2, 1958, released certain liens and levies entered pursuant to the jeopardy assessment. The assessment, made June 19, 1958, was in the amount of $860,489.21, which included taxes, penalties...
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