ORDER
DOWD, District Judge.
This action was brought by the plaintiff taxpayer as an action for judicial review of a jeopardy assessment made by the IRS against the plaintiff's property. Such an action is governed by a specialized statutory procedure found at 26 U.S.C. § 7429(b). In the ordinary case the district court must determine two things:
1. whether the making of the assessment is reasonable under the circumstances, and
2. whether...
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