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Enochs v. Williams Packing & Nav. Co., Inc., 370 U.S. 1 (1962)

Enochs v. Williams Packing & Navigation Co., Inc.

No. 493

Argued April 18, 1962

Decided May 28, 1962

370 U.S. 1


Respondent, which is in the business of providing fishing trawlers to commercial fishermen, sued in a Federal District Court to enjoin the collection of social security and unemployment taxes claimed by petitioner to be past due. Although petitioner adduced evidence in support of his claim that there was an employment relationship, the District Court found that such taxes were not, in fact, payable and that their collection would destroy respondent's business; and it permanently enjoined their collection.

Held: the suit for injunction was barred by § 7421(a) of the Internal Revenue Code of 1954, and a judgment sustaining the injunction is reversed. Miller v. Standard Nut Margarine Co., 284 U. S. 498, distinguished. Pp. 370 U. S. 1-8.

291 F.2d 402, reversed.

Page 370 U. S. 2

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