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U.S. v. ASMAR

No. 86-5585.

827 F.2d 907 (1987)

UNITED STATES of America, Appellant, v. Robert ASMAR and Kathleen Asmar.

United States Court of Appeals, Third Circuit.

Decided August 27, 1987.

Attorney(s) appearing for the Case

Roger M. Olsen, Asst. Atty. Gen., Michael L. Paup, Chief, Appellate Section, Richard J. Driscoll (Argued), Richard Farber, U.S. Dept. of Justice, Tax Div., Washington, D.C., for appellant; Thomas W. Greelish, U.S. Atty., of counsel.

Richard L. Friedman (Argued), Sharlene A. Hunt, Giordano, Halleran & Ciesla, Middletown, N.J., for appellee Kathleen Asmar.

Before SLOVITER, BECKER and GARTH, Circuit Judges.

OPINION OF THE COURT

GARTH, Circuit Judge:

This appeal arises from a civil action brought by the IRS against Robert and Kathleen Asmar seeking judgment for income tax deficiencies, penalties and interest for the years 1965-1968. Kathleen Asmar Rosenbaum (Asmar), among other defenses, asserts that the IRS was estopped to obtain judgment against her.

The acts that Asmar claims constitute estoppel are a series of representations made to her by low-level...

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