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LAING v. UNITED STATES

No. 73-1808.

423 U.S. 161 (1976)

LAING v. UNITED STATES ET AL.

Supreme Court of United States.

Reargued October 15, 1975.

Decided January 13, 1976.

Attorney(s) appearing for the Case

Joseph S. Oteri reargued the cause for petitioner in No. 73-1808. With him on the brief were Rudolph F. Pierce and Charlotte A. Perretta. Stuart A. Smith reargued the cause for the United States et al. in both cases. With him on the brief were Solicitor General Bork and Assistant Attorney General Crampton. Donald M. Heavrin reargued the cause and filed a brief for respondent in No. 74-75.

MR. JUSTICE MARSHALL delivered the opinion of the Court.

These companion cases involve two taxpayers whose taxable years were terminated by the Internal Revenue Service (IRS) prior to their normal expiration date pursuant to the jeopardy-termination provisions of § 6851 (a) (1) of the Internal Revenue Code of 1954 (Code), 26 U. S. C. § 6851 (a) (1).1 Section 6851 (a) (1) allows the IRS immediately to terminate a taxpayer's taxable...

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