U.S. v. HANS

No. 90-3042.

921 F.2d 81 (1990)

UNITED STATES of America, Plaintiff-Appellant, v. Joseph H. HANS, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 14, 1990.


Attorney(s) appearing for the Case

Albert Ritcher, Office of the U.S. Atty., Columbus, Ohio, Gary R. Allen, Acting Chief, Richard Farber, Kimberly S. Stanley, U.S. Dept. of Justice, Appellate Section Tax Div., Henry J. Riordan, Tax Div., U.S. Dept. of Justice, Washington, D.C., for plaintiff-appellant.

Joseph H. Hans, Columbus, Ohio, for defendant-appellee.

Before JONES and RYAN, Circuit Judges, and WISEMAN, District Judge.


RYAN, Circuit Judge.

In this action to reduce to judgment federal income tax assessments made against taxpayer Joseph H. Hans, the district court denied in part the government's motion for summary judgment against taxpayer Hans, on the ground that the statute of limitations had run with respect to one of the government's claims.

The issue on appeal is whether a decision of the tax court becomes "final" within the meaning of I.R.C. § 6503(a) on 1) the...

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