E. C. Lloyd v. George D. Patterson, District Director of Internal Revenue, District of Alabama

This is an appeal by Lloyd from an order sustaining appellee’s motion to dismiss Lloyd’s complaint which sought an injunction restraining the appellee from collecting any taxes under a jeopardy assessment and federal tax lien filed, together with directions to appellee to void the tax lien and to release or abate the lien to the extent of $15,000 to cover expense incurred and to be incurred by Lloyd in connection with civil and criminal proceedings then pending in the Tax Court and District Court in Alabama, respectively. The motion to dismiss was based upon the grounds that the suit was…