District Court, E.D. Wisconsin August 22, 1983, Civ. A. No. 83-C-762 (Peters v. United States)

DECISION and ORDER

TERENCE T. EVANS, District Judge.

On April 28, 1983, the Internal Revenue Service made a jeopardy assessment, authorized by § 6861(a) of the Internal Revenue Code, against the plaintiff Anthony J. Peters. Peters was assessed taxes, penalties and interest for 1981 and 1982. The assessments included $123,350.62 in taxes, $61,675.31 in fraud penalties, and $25,-052.