"Narcotics Offenders and the Internal Revenue Code: Sheathing the Secti" by John M. Fite

Article Title

Narcotics Offenders and the Internal Revenue Code: Sheathing the Section 6851 Sword

Authors

First Page

363

Abstract

This Note first will analyze the Internal Revenue Code provisions supporting the current crackdown by the IRS on suspected narcotics dealers. Secondly, it will examine the split in the federal circuit courts of appeal on the issues of the availability of Tax Court review of an assessment made pursuant to a section 6851 termination of a taxable year and the availability of equitable or statutory protections to prevent the seizure and sale of property belonging to the taxpayer. Lastly, a discussion of the propriety of such conduct by the IRS and its constitutionality in light of recent Supreme Court decisions concerning due process of law and prejudgment seizure of property will be followed by specific criticisms of the activity and suggestions for congressional or Supreme Court intervention.'

Recommended Citation

John M. Fite, Narcotics Offenders and the Internal Revenue Code: Sheathing the Section 6851 Sword, 28 Vanderbilt Law Review 363 (1975)
Available at: https://scholarship.law.vanderbilt.edu/vlr/vol28/iss2/3

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