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VICKNAIR v. UNITED STATES

Nos. 78-2684, 78-2685.

617 F.2d 1129 (1980)

Felix B. VICKNAIR and FBV Corporation, Individually, and as nominee for Felix B. Vicknair, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

May 27, 1980.

Attorney(s) appearing for the Case

Joel Hirschhorn, Miami, Fla., for plaintiffs-appellants.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Acting Chief, Appellate Section, Crombie J. D. Garrett, Philip I. Brennan, Leonard J. Henzke, Jr., Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant-appellee.

Before AINSWORTH and POLITZ, Circuit Judges, and SMITH, District Judge.

POLITZ, Circuit Judge:

Appellants Felix B. Vicknair and FBV Corporation were served with jeopardy assessments pursuant to 26 U.S.C. § 68611 for the tax years 1975 and 1976, in the total sum of $313,686.38. They sought administrative review of the assessments in accordance with the provisions of 26 U.S.C. § 7429.2 When the assessments were upheld they sought...

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