Bauer v. Foley

HENDERSON, Chief Judge.

The plaintiff has commenced this action to enjoin the government from seizing and selling her property and to have the assessments made against her declared void. The government opposes the application for the injunction and has moved to dismiss, claiming that the complaint fails to state a cause of action upon which relief can be granted; that the action is barred by the doctrine of sovereign immunity; that section 7421 (a) of the Internal Revenue Code of 1954 prohibits the relief sought and deprives this court of jurisdiction; and that the seizure and contemplated…