District Court, D. Arizona January 7, 1982, Civ. 81-508-TUC-MAR (Nolan v. United States)

ORDER

MARY ANNE RICHEY, District Judge.

Having heard the evidence presented at the judicial review proceeding December 2, 1981, and having considered all memoranda of law, the Court rules as follows:

Jeopardy and termination assessments against plaintiff-taxpayer are found to be reasonable, but the amount of the assessment is found to be inappropriate due to substantial doubts raised by plaintiff