United States Ninth Circuit

In this collection suit brought by the United States to reduce to judgment income tax assessments and to foreclose on certain properties, the district court's judgment in favor of the government is affirmed, where: 1) applying the Chevron analysis, the tolling period provided for in 26 U.S.C. section 6330(e)(1) includes the time during which a taxpayer could file an appeal to the Tax Court, even if the taxpayer does not actually file such an appeal; and 2) the government's action was therefore not barred by the ten-year statute of limitations because the running of the statute of limitations had been tolled.

Appellate Information

• Decided 12/16/2014
• Published 12/16/2014

Judges

Court

• United States Ninth Circuit

Counsel