Muse v. Enochs

MIZE, District Judge.

This matter is before the Court on motion of the plaintiffs for summary judgment to make perpetual and permanent the preliminary injunction heretofore entered herein, enjoining the defendant, James L. Enochs, as United States District Director of Internal Revenue for the District of Mississippi, from beginning any levy or proceedings in Court for the collection of an assessment of additions to tax for substantial underestimation or underpayment of estimated tax, where the defendant had not sent to the plaintiffs a ninety-day letter notifying them of the intention to make…