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LINDHOLM v. U.S.

Civ. A. No. 92-2136.

808 F.Supp. 3 (1992)

Magnus LINDHOLM, Plaintiff, v. UNITED STATES of America, and the Internal Revenue Service, Defendants.

United States District Court, District of Columbia.

October 8, 1992.

Attorney(s) appearing for the Case

Jay Stephens, U.S. Atty., Margaret M. Earnest, Tax Div., Dept. of Justice, Washington, DC, for U.S.

J. Roger Mentz, Linda E. Carlisle, McClure, Trotter & Mentz, Washington, DC.

Michael Quigley, Lucy W. Plisken, Akin, Gump, Hauer & Feld, Washington, DC.

ORDER

REVERCOMB, District Judge.

This is an action challenging a jeopardy assessment made against a nonresident alien by the Internal Revenue Service.

Background

On June 1, 1992, the Internal Revenue Service (IRS) made a jeopardy assessment against the plaintiff, a citizen of Sweden and a resident of the United Kingdom, pursuant to 26 U.S.C. § 6861. On September 18, 1992, the plaintiff filed this action under 26 U.S.C. §...

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