MEMORANDUM
WESLEY E. BROWN, District Judge.
FINDINGS OF FACT AND CONCLUSIONS OF LAW
This is a civil action under 26 U.S.C.A. § 7429 to review jeopardy assessment procedures taken by the Internal Revenue Service [IRS] in determining the 1980 tax liability of plaintiff, David W. Davis, pursuant to 26 U.S.C.A. § 6851.
The case arises out of a search conducted on July 23, 1980, by the Wichita Police Department at plaintiff's residence...
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