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RAMBO v. UNITED STATES

Nos. 73-1131, 73-1413.

492 F.2d 1060 (1974)

Charles R. RAMBO, Plaintiff-Appellee, v. UNITED STATES of America and District Director of Internal Revenue for the District of Kentucky, Defendants-Appellants.

United States Court of Appeals, Sixth Circuit.

Decided February 12, 1974.

Attorney(s) appearing for the Case

Richard Farber, Tax Div., Dept. of Justice, for defendants-appellants; Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Crombie J. D. Garrett, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief; George J. Long, U. S. Atty., of counsel.

David W. Gray, Louisville, Ky., for plaintiff-appellee; Michael J. Clare, Louisville, Ky., on brief.

Before CELEBREZZE and MILLER, Circuit Judges, and O'SULLIVAN, Senior Circuit Judge.

WILLIAM E. MILLER, Circuit Judge.

These consolidated appeals raise important and difficult questions concerning the statutory authority of the Internal Revenue Service to collect "jeopardy assessments" and the procedural safeguards available to the taxpayer.

Charles Rambo, the taxpayer-appellee, was arrested on April 6, 1972, for reckless driving. A search of his car and person revealed a supply of drugs and $2,200...

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