The following excerpt is from In re Return of Seized Prop., $4,000 in U.S. Currency, 130 F.Supp.3d 1354 (S.D. Cal. 2015):
of any tax.") (internal quotation marks omitted). "The manifest purpose of 7421(a) is to permit the United States to assess and collect taxes alleged to be due without judicial intervention, and to require that the legal right to the disputed sums be determined in a suit for refund." Enochs v. Williams Packing & Nav. Co., 370 U.S. 1, 7, 82 S.Ct. 1125, 8 L.Ed.2d 292 (1962).
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