OPINION
FRYE, District Judge:
Plaintiff, Brent J. Mesher, commenced this action pursuant to 26 U.S.C. § 7429 to obtain summary review of a jeopardy assessment made against him for unpaid federal income taxes and the penalties thereon for the tax years 1981 through 1988 in the aggregate total amount of $1,105,371.00. The government moves for summary judgment (# 16) on the grounds that no genuine issue of material fact remains with regard to the reasonableness...
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