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BORG-WARNER CORP. v. C. I. R.

No. 80-1818.

660 F.2d 324 (1981)

BORG-WARNER CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided September 29, 1981.

Attorney(s) appearing for the Case

Nora A. Bailey, Ivins, Phillips & Barker, Washington, D. C., for petitioner-appellant.

Richard W. Perkins, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D. C., for respondent-appellee.

Before SPRECHER, Circuit Judge, CUDAHY, Circuit Judge, and WILL, Senior District Judge.

WILL, Senior District Judge.

This is an appeal from the United States Tax Court's decision in favor of the Commissioner of Internal Revenue (Commissioner) in the amount of $4,316,132.06. The sole issue on this appeal is whether the assessed deficiency in the taxpayer's income tax for the year 1968 was barred by the statute of limitations under 26 U.S.C. § 6501.1 For the reasons stated herein...

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