United States Eleventh Circuit

In suit to reduce certain tax assessments to judgment, and counterclaim for tax refunds, orders granting summary judgment for the government on its complaint and counts in counterclaim are affirmed over claims that: 1) the applicable statute of limitations had expired prior to the government's suit; 2) lower court erred in dismissing counterclaim based on finding that defendant did not follow the proper administrative claim procedure as a prerequisite to his first eight claims; and 3) defendant did not show he overpaid any tax and was not entitled to exemption from levy.

Appellate Information

• Decided 03/12/2007
• Published 03/12/2007

Judges

• PER CURIAM:, Before ANDERSON and MARCUS, Circuit Judges, and ALTONAGA, District Judge.

Court

• United States Eleventh Circuit

Counsel

• For Appellant:
  
• Keith Howard Johnson, Johnson & Johnson, P.A., Jacksonville, FL, for Ryals., Deborah K. Snyder, Bruce R. Ellisen, Frank Phillip Cihlar, U.S. Dept. of Justice, App. Tax Div., Washington, DC, E. Bryan Wilson, U.S. Atty., Tallahassee, FL, for U.S.