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PERLOWIN v. SASSI

No. 82-4530.

711 F.2d 910 (1983)

Bruce PERLOWIN, Plaintiff-Appellee, v. Michael D. SASSI, District Director of Internal Revenue, San Francisco, California, and United States of America, Defendants-Appellants.

United States Court of Appeals, Ninth Circuit.

Decided July 29, 1983.

Attorney(s) appearing for the Case

Herbert L. Zuckerman, Sills, Beck, Cummins, Zuckerman, Radin & Tischman, P.A., Newark, N.J., for plaintiff-appellee.

Terry L. Fredricks, Dept. of Justice, Washington, D.C., for defendants-appellants.

Before ANDERSON, SKOPIL and NORRIS, Circuit Judges.

PER CURIAM:

Taxpayer brought this action seeking to have a termination assessment decision declared invalid and to have the Internal Revenue Service enjoined from enforcing the assessment. The district court declared the assessment invalid, restrained the IRS from attempting any further collections pursuant to the assessment and ordered return of all seized assets. Perlowin v. Sassi, 544 F.Supp. 89 (N.D.Cal.1982).

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