OPINION AND ORDER
GIERBOLINI, District Judge.
Plaintiff brought this action under 26 U.S.C. § 7429(b), to review a jeopardy assessment and termination notice sent to him by the Internal Revenue Service (IRS). On June 21, 1985, the IRS notified plaintiff that it was performing a jeopardy assessment of his tax liability and terminating the taxable year of 1985. The IRS had concluded that plaintiff appeared to be
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