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KRIVACEK v. UNITED STATES

No. CV 80-5628-AWT.

508 F.Supp. 246 (1981)

Michael Bradley KRIVACEK and Harold Goldstein, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, C. D. California.

February 12, 1981.

Attorney(s) appearing for the Case

M. Sean McMillan, Loo, Merideth & McMillan, Los Angeles, Cal., for plaintiffs.

Andrea Sheridan Ordin, U. S. Atty., Charles H. Magnuson, Asst. U. S. Atty., Chief, Tax Division, Kenneth M. Barrish, Asst. U. S. Atty., Los Angeles, Cal., for defendant.

MEMORANDUM AND ORDER

TASHIMA, District Judge.

This is a summary proceeding pursuant to § 7429(b) of the Internal Revenue Code, 26 U.S.C. § 7429(b) (all subsequent statutory references are to the Internal Revenue Code of 1954, as amended) to review termination assessments, § 6851, against plaintiff-taxpayers. After an accelerated discovery program permitting depositions to be taken on shortened notice, this matter was heard on January 5, 1981...

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