Civ. A. No. C78-1811A.

462 F.Supp. 845 (1978)

FIDELITY EQUIPMENT LEASING CORPORATION and Subsidiaries and Global Industries, Inc. and Subsidiaries, Plaintiffs, v. UNITED STATES of America and John W. Henderson, As District Director of the Internal Revenue Service, Defendants, Intervenor Georgia Ann Harmon, as trustee of an inter vivos and an alimony trust created by Michael G. Thevis.

United States District Court, N. D. Georgia, Rome Division.

December 20, 1978.

Attorney(s) appearing for the Case

Edward T. M. Garland, John R. Martin, and Robert W. Hassett of Garland, Nuckolls, Kadish & Cook, David F. Rock, Atlanta, Ga., for plaintiffs.

William W. Taylor, III of Zuckerman, Spaeder & Taylor, Washington, D.C., for intervenor.

William L. Harper, U. S. Atty., Atlanta, Ga., Richard F. Mitchell, Tax Div., Dept. of Justice, Washington, D.C., for defendants.


HAROLD L. MURPHY, District Judge.

On October 23, 1978, the plaintiffs filed a complaint to determine the reasonableness and appropriateness of two jeopardy assessments for income tax levied against them by the Internal Revenue Service on August 9, 1978. Jurisdiction of the Court was invoked pursuant to 26 U.S.C. § 7429(b).

These jeopardy assessments were made by the District Director of the Internal Revenue Service...

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