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SETTIPANE v. U.S.

No. CIV.A. 04-10188-REK.

352 F.Supp.2d 27 (2004)

Richard SETTIPANE, II, Plaintiff v. UNITED STATES of America, Defendant

United States District Court, D. Massachusetts.

December 7, 2004.

Attorney(s) appearing for the Case

Francis J. DiMento, Jason A. Kosow, DiMento & Sullivan, Boston, MA, for Richard Settipane, II Plaintiff.

Glenn J. Melcher, U.S. Department of Justice, Washington, DC, Barbara Healy Smith, United States Attorney's Office, Boston, Stephen J. Turanchik, U.S. Department of Justice, Washington, DC, for the United States of America, Defendant.

Findings of Fact and Conclusions of Law

KEETON, Senior District Judge.

This matter came before the court for judicial review of a jeopardy assessment made by the Internal Revenue Service ("IRS") against the Plaintiff, Richard Settipane, II ("Plaintiff"), for the tax years 1997 through 2002. The court held a bench trial. Upon full hearing and consideration of this matter the court reaches the following Findings of Fact and Conclusions of Law:

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