E. GRADY JOLLY, Circuit Judge:
The United States brought this suit in district court in order to collect unpaid federal taxes owed by Malcolm McCallum. The district court granted the government's motion for summary judgment and entered judgment against the taxpayer.
On appeal, McCallum argues that the district court erred in granting summary judgment because the government filed its complaint out of time, because the assessments were unauthorized and procedurally...
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