MEMORANDUM
MORTON, Chief Judge.
This case is a petition for review of a termination assessment made against the plaintiff on May 2, 1983. On April 12, 1983, the District Director of the IRS notified the plaintiff that pursuant to 26 U.S.C. § 6851 the taxable period from January 1, 1983, through April 4, 1983, was being terminated and that taxes in the amount of $163,149.01 were being assessed. In accordance with the plaintiff's request, an IRS appeals...
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