Springer V. United States - Background

Background

William M. Springer had filed a Federal income tax return for the tax year 1865 showing $50,798 in income and $4,799 in income tax, but refused to pay the tax. Springer's income was from two sources: income in his profession as an Attorney at law, and interest income on United States bonds.

After Springer's failure to pay the tax, the Federal tax collector advertised Springer's properties for sale to satisfy the tax liability. In 1867 and 1874, the tax collector sold two pieces of real estate owned by Springer in Springfield, Illinois (one of which was Springer's residence), apparently without physically seizing the properties or ejecting Springer from the properties. The properties were deeded by the tax collector to the United States government. One of the deeds recited the statutory authority for the sale as being an Act of Congress of "July 1, 1862" as amended by an Act of "March 30, 1864."

In 1874, the government filed a lawsuit of ejectment against Springer with respect to the previously sold properties. In the ejectment action, Springer challenged the constitutionality of the 1864 Act.

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