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SELBE v. U.S.

Civ. A. No. 92-0638-R.

899 F.Supp. 1524 (1995)

Frank G. SELBE, III, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Virginia, Roanoke Division.

June 9, 1995.

Attorney(s) appearing for the Case

Frank G. Selbe, III, Roanoke, VA, pro se.

Richard A. Lloret, U.S. Attorney's Office, Roanoke, VA, William K. Rounsborg, Trial Attorney, Margaret M. Earnest, U.S. Department of Justice, Tax Division, Washington, DC, for defendant United States of America.

MEMORANDUM OPINION

KISER, Chief Judge.

On April 2, 1992, the Internal Revenue Service ("IRS") made a jeopardy assessment against the plaintiff, Frank G. Selbe III, for unpaid federal income tax from the years 1983 and 1984, under 26 U.S.C. § 6861. Selbe sought administrative review and was denied relief. He then filed the instant action seeking a judicial determination regarding the reasonableness of the jeopardy assessment and the amount assessed...

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