Owen J. Roberts, Rickert Rice Mills v. Fontenot…
“ We have no occasion to discuss or decide whether section 21 (d) affords an adequate remedy at law. As yet the petitioner has not paid the taxes to the respondent, and, in view of the decision in the Butler Case, hereafter cannot be required so to do. If the respondent should now attempt to collect the tax by distraint, he would be a trespasser. ”
