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MORSE v. INTERNAL REVENUE SERVICE

No. 80-1283.

635 F.2d 701 (1980)

Jo Ann MORSE, Appellant, v. INTERNAL REVENUE SERVICE, Paul D. Williams, Joe Woolsey and Gus McClanahan, Appellees.

United States Court of Appeals, Eighth Circuit.

Decided December 16, 1980.

Attorney(s) appearing for the Case

Ball & Mourton, Deborah Wikstrom, Fayetteville, Ark., for appellant.

M. Carr Ferguson, Asst. Atty. Gen., Gilbert E. Andrews, Daniel F. Ross, Kristina E. Harrigan, Attys., Tax Division, Dept. of Justice, Washington, D. C., for appellees.

Before BRIGHT and STEPHENSON, Circuit Judges, and LARSON, Senior District Judge.

BRIGHT, Circuit Judge.

I. Background.

Jo Ann Morse brought this action in federal district court to enjoin the collection of $18,416.35 in income tax deficiencies assessed by the Internal Revenue Service for the tax years 1973, 1974, and 1975. The Government moved to dismiss her action for lack of subject matter jurisdiction, arguing that section 7421 of the Internal Revenue Code of 1954, commonly known as...

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