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VALLEY FINANCE, INC. v. UNITED STATES

Nos. 78-1585, 79-1151 and 79-1301.

629 F.2d 162 (1980)

VALLEY FINANCE, INC. et al., Appellants, v. UNITED STATES of America et al. PACIFIC DEVELOPMENT, INC., Appellant, v. UNITED STATES of America et al. PACIFIC DEVELOPMENT, INC., Appellant, v. UNITED STATES of America et al.

United States Court of Appeals, District of Columbia Circuit.

Decided July 14, 1980.

Rehearing Denied September 9, 1980.

Attorney(s) appearing for the Case

Walter T. Charlton, Washington, D. C., and Richard T. Sampson, Baltimore, Md., with whom E. William Tupling, Washington, D. C., was on brief, for appellants.

Daniel F. Ross, Atty., Dept. of Justice, with whom M. Carr Ferguson, Asst. Atty. Gen., Carl S. Rauh, U. S. Atty. at the time brief was filed, and Crombie J. D. Garrett, Washington, D. C., were on brief, for appellees. Charles F. C. Ruff, U. S. Atty., and Myron C. Baum, William A. Friedlander, S. Martin Teel, Jr., Attys., Dept. of Justice, Washington, D. C., also entered appearances for appellees.

Before TAMM and MIKVA, Circuit Judges and GESELL, United States District Court Judge for the District of Columbia.

Opinion for the Court filed by District Judge GESELL.

GESELL, District Judge:

These companion appeals were consolidated for argument with consent of counsel and will be dealt with in a single opinion. They arise from a jeopardy assessment for income taxes exceeding 4.5 million dollars made by the Internal Revenue Service ("IRS") against one Tongsun Park on January 18, 1977. The IRS seized assets of Pacific Development, Inc. ("Pacific"), a corporation wholly...

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