Opinion of the Court. 331 U.S. completion of the Tax Court proceedings or a test suit against a customer. Whether or not there will be any injury in this limited respect depends of course, first, on the outcome of the Tax Court proceedings, particularly in relation to the matters of coverage; second, on whether, upon the assumption that those proceedings sustain the Government's claim as to all or part of the $270,000, the amount thus found due is finally held, in authorized litigation, to be due and owing to the appellant or to the Government. And, as we have also said, if that result should favor the appellant, the Government's obligation to indemnify the contractor would be, in effect, indirectly available to appellant to indemnify it for any loss of the use of the moneys withheld.45 Whatever might be true in other circumstances, this showing as to the necessity for suing many customers is hardly sufficient to justify the substitution of equity's extraordinary relief for what in all the conditions of this case appears to be a full, adequate and completely available remedy at law. Coffman v. Breeze Corporations, supra; Macauley v. Waterman S. S. Corp., supra. Indeed the argument of multiplicity, with others, was expressly advanced and rejected in the Waterman case, as ground for not applying the Myers rule and for sustaining declaratory and equitable intervention to circumvent it. After noting the company's claim, with others, that "it would be subjected to a multiplicity of suits in order to recover the money due on the contracts," we there said: "Even if one or all of these things might possibly occur in the future, that possibility does not affect the application. of the rule requiring exhaustion of administrative remedies. The District Court had no power to determine in this proceeding and at this time issues that might arise 45 See note 43 supra. 752 Opinion of the Court. because of these future contingencies." 327 U. S. at 545. This case is perhaps even stronger than the Waterman case for application of the Myers rule. For here the appellant is a subcontractor retaining what the contractor complainant did not have in the Waterman case, namely, a completely adequate remedy at law against its customers, buttressed by the Government's guaranty of indemnity to the contractor for all liability incurred by him on account of withholding funds allegedly due the appellant. In view of that fact the further one that constitutional issues are included among those tendered in this case but were not presented in the Waterman case, becomes wholly immaterial. To countenance short-circuiting of the Tax Court proceedings here would be, under all the circumstances but more especially in view of Congress' policy and command with respect to those proceedings, a long overreaching of equity's strong arm. The judgment is MR. JUSTICE JACKSON Concurs in the result. MR. JUSTICE DOUGLAS dissents. Affirmed. DECISIONS PER CURIAM, ETC., FROM APRIL 8, 1947, THROUGH JUNE 23, 1947.* No. 1229. PEETE V. CALIFORNIA. April 10, 1947. Petition for writ of certiorari to the Supreme Court of California denied. The motion for a stay is also denied. Morris Levine for petitioner. No. 129, Misc. EX PARTE ROCKOWER. April 14, 1947. The request of the petitioner for leave to withdraw the application filed herein is granted. No. 133, Misc. EX PARTE FAHEY ET AL. April 14, 1947. A rule is ordered to issue, returnable Monday, April 28, next, requiring the respondents to show cause why leave to file the petition for writ of mandamus and/or prohibition and/or injunction should not be granted. The cause is assigned for argument on the return to the rule immediately following the hearing in Fahey v. Mallonee, No. 687. All proceedings tending to effectuate the order of the District Judge granting a motion with respect to costs and expenses of certain appellees in case No. 687 and counsel fees are hereby stayed pending the further order of this Court. Acting Solicitor General Washington for petitioners. *MR. JUSTICE DOUGLAS took no part in the consideration or decision of cases in which judgments or orders hereinafter reported were announced on May 12 and 19, 1947, with the exception of cases No. 11, original, and No. 715, post, p. 788. For orders on applications for certiorari, see post, pp. 797, 805; rehearing, post, p. 863. Decisions Per Curiam, Etc. 331 U.S. No. 1143. UNITED STATES v. MT. CLEMENS POTTERY Co. ET AL. April 14, 1947. Petition for writ of certiorari to the Circuit Court of Appeals for the Sixth Circuit dismissed on motion of counsel for the petitioner. Attorney General Clark for the United States. Reported below: 149 F.2d 461. No. 512. RALEY ET AL., TRADING AS RALEY'S FOOD STORE, V. FLEMING, TEMPORARY CONTROLS ADMINISTRATOR. Certiorari, 329 U. S. 705, to the United States Court of Appeals for the District of Columbia. April 28, 1947. Motion to vacate order of this Court substituting Fleming for Porter denied. No. 1223. CHELTENHAM & ABINGTON SEWERAGE Co. v. PENNSYLVANIA PUBLIC UTILITY COMMISSION. from the Supreme Court of Pennsylvania; and Appeal No. 1230. NEWTON OIL Co. v. BOCKHOLD ET AL. Appeal from the Supreme Court of Colorado. April 28, 1947. Per Curiam: The motions to dismiss are granted and the appeals are dismissed. Treating the papers whereon the appeals were allowed as petitions for writs of certiorari as required by § 237 (c) of the Judicial Code, as amended, 28 U. S. C. § 344 (c), certiorari is denied. George Henry Huft for appellant in No. 1223. Max P. Zall for appellant in No. 1230. Charles E. Thomas, Samuel Graff Miller and William McKelvy Rutter for appellee in No. 1223. Henry E. Lutz for appellees in No. 1230. Reported below: No. 1223, 355 Pa. 377, 49 A. 2d 707; No. 1230, 115 Colo. 510, 176 P. 2d 904. No. 1224. MOTOR HAULAGE CO., INC. v. UNITED STATES ET AL. Appeal from the District Court of the United |