SECURITY INDUS. INS. CO. v. U.S.

No. 86-3806.

830 F.2d 581 (1987)

SECURITY INDUSTRIAL INSURANCE COMPANY, Plaintiff-Appellant, v. UNITED STATES of America, et al., Defendants-Appellees.

United States Court of Appeals, Fifth Circuit.

October 23, 1987.


Attorney(s) appearing for the Case

F. Kelleher Riess, Metairie, La., for plaintiff-appellant.

John J. Boyle, Atty., Michael L. Paup, Chief, Appellate Section, Tax Div., Justice Dept., Roger M. Olsen, Asst. Atty. Gen., Robert S. Pomerance, Atty., Washington, D.C., for defendants-appellees.

Before WISDOM, GEE, and RANDALL, Circuit Judges.


GEE, Circuit Judge:

Security Industrial Insurance Co. ("the taxpayer") appeals the dismissal of this Enochs suit1 seeking to enjoin collection of federal income tax. We remand for dismissal.

I.

The taxpayer and the government entered into several agreements extending the three-year statute of limitations for the 1973 tax year. Under the last of these agreements, the limitation would run in December 1982. The government...

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