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SAGE v. U.S.

Nos. 89-2780, 89-6090.

908 F.2d 18 (1990)

John A. SAGE, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

August 13, 1990.

Attorney(s) appearing for the Case

Nancy G. Morgan, Gary R. Allen, Chief, Appellate Section, Tax Div., David Brunori, Atty., John Boyle and Seth G. Heald, U.S. Dept. of Justice, Washington, D.C., for U.S.

Edward D. Urquhart, Charles J. Escher, and Silvia T. Hassell, Houston, Tex., for John A. Sage.

Before THORNBERRY, GEE and BARKSDALE, Circuit Judges.

GEE, Circuit Judge:

Appellant John A. Sage obtained judgment in federal district court against the United States, the central holding of which was that the three-year statute of limitations in Section 6501(a) of the Internal Revenue Code barred the IRS's assessment of penalties against him pursuant to Section 6700. From that judgment the United States now appeals contending, in the main, that Section 6501(a) does not apply to bar Section 6700 penalties and that the...

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