BEHREN v. U.S.

No. 94-5022.

82 F.3d 1017 (1996)

Richard BEHREN, Leta Behren, Plaintiffs-Counter-Defendants-Appellants-Cross-Appellees, v. UNITED STATES of America, Defendant-Counterclaimant-Appellee-Cross-Appellant.

United States Court of Appeals, Eleventh Circuit.

May 9, 1996.


Attorney(s) appearing for the Case

Howard W. Gordon, Paul S. Berger, Semet, Lickstein, Morgenstern, Berger, Friend, Brooke & Gordon, Coral Gables, FL, for appellants.

Gary R. Allen, Patricia M. Bowman, Loretta C. Argrett, William S. Estabrook, Tax Division, Dept. of Justice, Washington, DC, for appellee.

Before ANDERSON and BARKETT, Circuit Judges, and YOUNG, Senior District Judge.


ANDERSON, Circuit Judge:

Taxpayers Richard and Leta Behren appeal from a judgment of the district court holding them liable to the government for taxes in the amount of $82,392.90. The sole issue addressed in this opinion is whether the 1990 amendment to the statute of limitations, Internal Revenue Code (26 U.S.C.) § 6502, extended the period for collection of the assessment in this case. We conclude that it did.

On November 28, 1984, the I.R.S. made...

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