In 1919, the Coombe Garment Company, a Pennsylvania corporation, distributed all of its assets among its stockholders, and then dissolved. D made deficiency assessments against it for income and profits taxes for the years 1918 and 1919. A small part of these assessments was collected, leaving an unpaid balance of $9,306.36. P had owned one-fourth of the company's stock and had received $17,139.61 as his distributive dividend. P was targeted for the entire remaining amount of the deficiencies. No other transferees and no suit or proceedings for collection was instituted against them. D was entitled a summary collection process which did not give P a hearing until after the taxes were collected. P claimed a violation of due process of law. The Board of Tax Appeals held that the estate was liable for the full amount. That was affirmed by Court of Appeals. The Supreme Court granted certiorari.