Leighton v. United States

In 1921 all assets of Leighton and Co., Inc., of California, were sold and the proceeds distributed pro rata among stockholders, including petitioners. Nothing remained ,to satisfy outstanding corporate obligations.

September, 1925, within the time permitted by statute, or written waivers, the Commissioner of Internal Reve nue notified the corporation of tax deficiencies for 1918, .1919, and 1920; and on January 16,1926, he assessed these against it. There was no contest. Efforts to enforce-payment by distraint were unsuccessful. The present equity suit seeks to compel petitioners severally to…