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HALL v. C.I.R. (DEPT. OF TREASURY)

No. 86-8275.

805 F.2d 1511 (1986)

Harry E. HALL, Plaintiff-Appellant, v. COMMISSIONER, INTERNAL REVENUE SERVICE (DEPARTMENT OF TREASURY), Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

December 16, 1986.

Attorney(s) appearing for the Case

Bruce S. Harvey, Atlanta, Ga., for plaintiff-appellant.

Michael L. Paup, Roger M. Olsen, Wynette J. Hewett, Seth G. Heald, Chief, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before GODBOLD and VANCE, Circuit Judges, and SWYGERT, Senior Circuit Judge.

CORRECTED OPINION

GODBOLD, Circuit Judge:

Hall appeals from the district court's dismissal of his suit seeking review pursuant to 26 U.S.C. § 7429 of termination and jeopardy assessment against him with respect to income taxes for the year 1984 and a § 6700 penalty for allegedly promoting "abusive" tax shelters.

On June 10, 1985 Hall filed an action pursuant to 26 U.S.C. § 7429 seeking a determination of the validity of the I.R.S....

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