UNITED STATES v. WEISS

No. 21-1592.

52 F.4th 546 (2022)

UNITED STATES of America v. Charles J. WEISS, Appellant.

United States Court of Appeals, Third Circuit.

Filed: November 2, 2022.


Attorney(s) appearing for the Case

Michael J. Haungs , John Schumann [ARGUED], United States Department of Justice, Tax Division, 950 Pennsylvania Avenue, N.W., P.O. Box 502, Washington, DC 20044, Counsel for United States of America.

James R. Malone, Jr. [ARGUED], Post & Schell, 1600 John F. Kennedy Boulevard, Four Penn Center, 14th Floor, Philadelphia, PA 19103, Counsel for Charles J. Weiss.

Before: GREENAWAY, JR., PORTER, and PHIPPS, Circuit Judges.


OPINION OF THE COURT

After assessing delinquent taxes, the United States has ten years to collect them, see 26 U.S.C. § 6502(a)(1), and this case comes down to a matter of days within that decade. Importantly, that limitations period does not necessarily run continuously; it may be tolled for several...

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