John B. Mathes v. United States

ATKINS, Senior District Judge:

This is an appeal from the district court’s dismissal of the taxpayer’s Complaint to enjoin the collection of federal income tax es. We affirm the district court’s dismissal and denial of injunctive relief based on lack of jurisdiction. The district court was precluded from exercising equitable jurisdiction because the taxpayer failed to avail himself of his adequate legal remedy; the taxpayer could have timely applied to the Tax Court for a redetermination of the alleged tax deficiencies. In reaching this result, we set aside the finding in Conclusion of Law No.…