ORDER
DEVITT, District Judge.
This is a jeopardy assessment action pursuant to 26 U.S.C. § 7429(b). At issue is whether the making of jeopardy assessments for 1983 through 1985 and a termination assessment for 1986 is reasonable under the circumstances and whether the amounts so assessed are appropriate under the circumstances.
Schmitt's action came on for summary hearing on June 8, 1987, at which time the court solicited from the parties facts...
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