Louis Colangelo v. United States of America

Because I feel that authorities do not compel and policy counsels against the court’s expansive reading of the “restraining . . . collection” language of the Anti-Injunction Act, 26 U.S.C. § 7421(a), I respectfully dissent. If the court, quoting United States v. Dema, 544 F.2d 1373, 1376 (7th Cir. 1976), were correct that an individual can never challenge any “activities which are intended to or may culminate in the assessment or collection of taxes”, then the government could adopt bizarre practices with impunity. Under the court’s logic the government could file a large tax lien for an…