United States Third Circuit

A taxpayer did not bring suit within 26 U.S.C. section 6532's two-year window of opportunity following the IRS's disallowance of his refund requests for relevant tax years, thus the Bankruptcy Court did not have jurisdiction over an adversary proceeding as to those years.

Appellate Information

• Decided 01/29/2003
• Published 01/29/2003

Judges

• Before BARRY, AMBRO and COWEN, Circuit Judges.

Court

• United States Third Circuit

Counsel

• For Appellant:
  
• Michael I. Saltzman, (Argued), White & Case LLP, New York, for Appellant.


• For Appellees:
  
• Eileen J. O'Connor, Assistant Attorney General, Gilbert S. Rothenberg, (Argued), Annette M. Wietecha, Andrea R. Tebbets, Department of Justice, Tax Division, Washington, for Appellee.