H & H Beverage Distributors, Inc. v. Department of Revenue

How later courts describe this case

• holding that defendant lacked constitutionally protected expectation of privacy in trash located approximately 4 feet from the back door of his trailer
• in a case under section 362, “Code contemplated that all governmental taxing entities should reeeive equal treatment”
• governmental unit may issue a notice of tax deficiency but may not attempt to collect a prepetition tax
• Pennsylvania’s issuance of “Notice of Audit Assessment” is not tantamount to a lien and therefore did not violate automatic stay
• police searched containers on defendant's property four feet from door of his home
• Commonwealth may assess tax obligation but not create a tax lien
• Pennsylvania tax law analogous to federal law