Commissioner v. Shapiro

This case presents questions relating to the scope of the Internal Revenue Code’s Anti-Injunction Act, 26 U. S. C. § 7421 (a),1 in the context of a summary seizure of a taxpayer’s assets pursuant to a jeopardy assessment. §§ 6861, 6331, 6213.

I

Normally, the Internal Revenue Service may not “assess” a tax or collect it, by levying on or otherwise seizing a taxpayer’s assets, until the taxpayer has had an opportunity to exhaust his administrative remedies, which include an opportunity to litigate his tax liability *617fully in the Tax Court, 26 U. S. C. §§ 6212, 6213;2 and if the Internal Revenue…