The following excerpt is from Johnson v. U.S., By and Through Dept. of Treasury IRS, 123 F.3d 700 (2nd Cir. 1997):
The statute might remit the Government to an action at law.... A judgment against [the taxpayer] might be collected by the levy of an execution. But taxes are the life-blood of government, and their prompt and certain availability an imperious need. Time out of mind, therefore, the sovereign has resorted to more drastic means of collection.
Bull v. United States, 295 U.S. 247, 259-60, 55 S.Ct. 695, 699, 79 L.Ed. 1421 (1935).
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