Massachusetts Superior Court March 1, 1996, No. CA 900785 (Iacaboni v. Commissioner of Revenue)

Brassard, J.

In 1989, the Commissioner of Revenue (“Commissioner”) made jeopardy assessments against the plaintiffs and filed corresponding liens and levies against their property. The Commissioner asserts that his claims grow out of the failure of the plaintiffs to file tax returns with respect to gaming income.