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HALL v. UNITED STATES

No. 73-1614.

493 F.2d 1211 (1974)

Elizabeth Jane HALL, Plaintiff-Appellee, v. UNITED STATES of America et al., Defendants-Appellants.

United States Court of Appeals, Sixth Circuit.

Decided March 12, 1974.

Attorney(s) appearing for the Case

Gary Allen, Dept. of Justice, for defendants-appellants; Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Crombie J. D. Garrett, Attys., Tax Div., Dept. of Justice, Washington, D. C., on brief; George J. Long, U. S. Atty., David L. Huber, Asst. U. S. Atty. of counsel.

Edwin F. Kagin, Jr., Louisville, Ky., for plaintiff-appellee; Donald M. Heavrin, Louisville, Ky., on brief; Michael D. Graves, Tulsa, Okl., of counsel.

Before WEICK, EDWARDS and LIVELY, Circuit Judges.

PER CURIAM.

This appeal is from a preliminary injunction granted by the District Court, restraining the sale of taxpayer's automobile and the collection of a jeopardy assessment made without any notice of deficiency, which assessment is alleged to be invalid because it compelled taxpayer to pay the tax without affording her a remedy in the Tax Court to determine its validity.

The Director of Internal Revenue Service...

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