KENNEDY, Circuit Judge:
The taxpayer, Harry Schildcrout, commenced this action in United States district court to enjoin the Internal Revenue Service from imposing a jeopardy assessment and from implementing the procedures necessary to enforce collection. The injunctive relief requested by the taxpayer was granted in part and denied in part by the district court.
The Internal Revenue Service imposed a jeopardy assessment against Schildcrout on March 31, 1973...
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