Elizabeth Jane Hall v. United States of America

This appeal is from a preliminary injunction granted by the District Court, restraining the sale of taxpayer’s automobile and the collection of a jeopardy assessment made without any notice of deficiency, which assessment is alleged to be invalid because it compelled taxpayer to pay the tax without affording her a remedy in the Tax Court to determine its validity.

The Director of Internal Revenue Service wrote to the taxpayer on February 1, 1973, stating that he found her involved in illicit drug activities tending to prejudice or render ineffectual the collection of 'income tax for the period…