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CLARKE v. UNITED STATES

Civ. A. No. 82-0664-R.

587 F.Supp. 674 (1984)

Samuel H. CLARKE v. UNITED STATES of America.

United States District Court, E.D. Virginia, Richmond Division.

March 13, 1984.

Attorney(s) appearing for the Case

Sa'ad El-Amin, El-Amin, Palmer & Buchanan, Richmond, Va., for plaintiff.

G. Wingate Grant, Asst. U.S. Atty., Richmond, Va., for defendant.

ORDER AND OPINION

WARRINER, District Judge.

This proceeding commenced with the filing of a complaint by plaintiff under the provisions of 26 U.S.C. § 7429. Having been subjected to a "jeopardy assessment" by the IRS, plaintiff sought the summary judicial inquiry provided by Congress. The statute,1 upon the filing of the complaint, places the burden upon the government to prove...

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