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STONE v. UNITED STATES

No. 74 Civ. 3643.

405 F.Supp. 642 (1975)

Andrew L. STONE and M. Jeanne Stone, Plaintiffs, v. UNITED STATES of America and District Director of Internal Revenue, Manhattan District, Defendants.

United States District Court, S. D. New York.

December 2, 1975.

Attorney(s) appearing for the Case

Wagman, Cannon & Musoff, P.C., New York City, for plaintiffs; Wallace Musoff, New York City, of counsel.

Paul J. Curran, U. S. Atty., S.D.N.Y., New York City, for defendants; William G. Ballaine, Asst. U. S. Atty., of counsel.

OPINION

EDWARD WEINFELD, District Judge.

Plaintiffs, Andrew L. Stone and M. Jeanne Stone, husband and wife, commenced this action against the United States of America and the District Director of Internal Revenue for a judgment (1) enjoining the defendants from enforcing, by lien, levy or otherwise, a jeopardy assessment made against plaintiffs for income deficiencies, interest and penalties totalling $7,108,861.73 for the taxable years 1963 through 1967...

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