United States v. Plisco

MORRIS, District Judge.

This suit was brought by the United States for a judgment for unpaid taxes, penalties and interest, alleged to be due and owing by the defendant for the taxable years 1948, 1949 and 1950. *415The defendant has moved to dismiss the complaint, contending that, because his claim for refund, which he made following assessments and collections by administrative distraint proceedings (seizure of two bank accounts and an automobile), is presently under administrative review before the Bureau of Internal Revenue, this action is premature and should not be considered until an…