District Court, N.D. Illinois July 7, 2004, 04 C 3453 (Wellek v. United States)

MEMORANDUM OPINION AND ORDER

ST. EVE, District Judge.

In April 2004, the Internal Revenue Service (“IRS”) issued a jeopardy assessment and jeopardy levy upon approximately $12,000,000 of Plaintiffs seized cash to satisfy past due tax obligations totaling $11,537,250.16. Plaintiff filed a complaint pursuant to 26 U.S.C.