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LICAVOLI v. NIXON

Civ. A. No. 21595.

201 F.Supp. 835 (1962)

Peter LICAVOLI and Grace Licavoli, his wife, Plaintiffs, v. R. I. NIXON, District Director, Internal Revenue Service, Detroit, Michigan, and United States of America, Defendants.

United States District Court E. D. Michigan, S. D.

January 3, 1962.

Attorney(s) appearing for the Case

John F. Noonan, Detroit, Mich., for plaintiffs.

Lawrence Gubow, U. S. Atty., William H. Merrill, Asst. U. S. Atty., Detroit, Mich., for defendants.

THORNTON, District Judge.

This action was instituted approximately one month subsequent to the making, levying and assessing of jeopardy assessments against plaintiffs in the amount of $411,162.58 by the defendant District Director pursuant to Section 6861 of the Internal Revenue Code of 1954. It is the claim of plaintiffs, as set forth in their complaint, that said jeopardy assessments "constitute an illegal claim against plaintiffs' property for the reasons hereinafter...

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