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UNITED STATES v. GALLETTI

No. 02-1389.

541 U.S. 114 (2004)

UNITED STATES v. GALLETTI ET AL.

Supreme Court of United States.

Decided March 23, 2004.

Attorney(s) appearing for the Case

Kent L. Jones argued the cause for the United States. With him on the briefs were Solicitor General Olson, Assistant Attorney General O'Connor, Deputy Solicitor General Hungar, Thomas J. Clark, and Andrea R. Tebbets.

David R. Haberbush argued the cause for respondents. With him on the brief were Joel Barry Feinberg, A. Lavar Taylor, and Charles F. Rosen.

THOMAS, J., delivered the opinion for a unanimous Court.

JUSTICE THOMAS delivered the opinion of the Court.

Section 6501(a) of the Internal Revenue Code states that, except as otherwise provided, "the amount of any tax imposed by this title shall be assessed within 3 years after the return was filed . . . and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period." 26 U.S.C. § 6501(a). If a tax is properly assessed within three years, however, the...

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