(DOWNLOAD) "United States v. Ressler" by United States Court of Appeals for the Fifth Circuit # eBook PDF Kindle ePub Free
eBook details
- Title: United States v. Ressler
- Author : United States Court of Appeals for the Fifth Circuit
- Release Date : January 14, 1978
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 56 KB
Description
On August 1, 1975, the United States filed this civil suit to collect unpaid taxes and to set aside as fraudulent certain conveyances of real property made by defendant Ressler. After a nonjury trial, the district judge found that the conveyances of the real property were fraudulent as to the United States and therefore rendered null and void by Florida law, and that defendant Ressler is indebted to the United States for tax liabilities in the amount of $33,619.01 plus statutory additions. Defendants appealed. The sole issue which we discuss on this appeal is whether this suit is barred by the Internal Revenue Code's six-year statute of limitations for collection after assessments, 26 U.S.C.A. § 6502(a), since the bulk of the assessments involved were assessed more than six years prior to the commencement of this action. We hold that the action was timely, because the statute of limitations was extended by an agreement between defendant Ressler and the Government to beyond the date on which the complaint was filed.
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