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BURD v. U.S.

Civ. No. 91-3264 (CSF).

774 F.Supp. 903 (1991)

Elena Zahos BURD, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. New Jersey.

October 8, 1991.

Attorney(s) appearing for the Case

Mortenson and Associates, P.C. by Charles Edward Falk, Cranford, N.J., for plaintiff.

Michael Chrertoff, U.S. Atty. by Susan Cassell, Asst. U.S. Atty., Newark, N.J., Beverly A. Moses, Richard L. Gilman, Trial Attys., Tax Div., U.S. Dept. of Justice, Washington, D.C., for defendant.

OPINION

CLARKSON S. FISHER, District Judge.

Before this court is a motion by plaintiff, Elena Zahos Burd, to deny the United States' motion for summary determination and in support of plaintiff's motion for summary determination. The issue presented in this action is whether the Internal Revenue Service's jeopardy assessment pursuant to 26 U.S.C. § 6862 was reasonable under the circumstances. For the following reasons, the court determines that the...

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