MEMORANDUM OPINION
DAN M. RUSSELL, District Judge.
In this action, the plaintiff-taxpayer seeks judicial review of jeopardy and termination assessments made against her by the Internal Revenue Service. Jurisdiction is predicated upon 26 U.S.C. § 7429. The complaint requests that the Court determine whether the making of jeopardy assessments under 26 U.S.C. § 6861 and a termination assessment under 26 U.S.C. § 6851 is reasonable under the circumstances...
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