DECISION AND ORDER
REYNOLDS, Chief Judge.
This is an action brought by the Government to reduce a federal tax jeopardy assessment made pursuant to 26 U.S.C. § 6851 against LeRoy Doyle ("taxpayer") to judgment.
On January 25, 1980, this Court granted the Government's motion for a summary determination pursuant to the statutory procedure set forth in 26 U.S.C. § 7429 that the jeopardy assessment issued on August 16, 1978, against the taxpayer...
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