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Phillips v. Commissioner of Internal Revenue

United States Supreme Court
283 U.S. 589 (1931)


Facts

The federal commissioner of the Internal Revenue Service (Commissioner) (defendant) assessed back taxes against I. L. Phillips (plaintiff). After Phillips died, the executors of his estate (plaintiffs) petitioned the Board of Tax Appeals (Board) for an administrative redetermination of the assessment. The Board upheld the Commissioner’s assessment. Under a 1926 federal tax law, later repealed, the Board's administrative decision entitled the Commissioner to a summary collection of the back taxes. This summary-collection process did not give the estate an opportunity for a judicial hearing on the correctness of the Board's administrative decision until after the back taxes had been collected. The estate sued the Commissioner to prevent the summary collection, contending that the lack of a preliminary judicial hearing would deprive the estate of due process, in violation of the Fifth Amendment to the United States Constitution. The United States Circuit Court of Appeals for the Second Circuit ruled for the Commissioner. The United States Supreme Court granted certiorari to resolve a conflict between lower court decisions.

Rule of Law

Issue

Holding and Reasoning (Brandeis, J.)

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