ORDER DENYING DEFENDANT'S MOTION TO DISMISS; GRANTING PLAINTIFFS' MOTION FOR ABATEMENT OF JEOPARDY ASSESSMENT
RHOADES, District Judge.
BACKGROUND
On February 2, 1990, plaintiffs filed a complaint to determine the reasonableness and appropriateness of two jeopardy assessments levied against them by the Internal Revenue Service ("IRS"). The jeopardy assessment made by the IRS against Stebco, Inc. ("Stebco...
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