United States v. Anthony J. J. A. Wilson, 304 F.2d 530, 3rd Cir. (1962)
United States v. Anthony J. J. A. Wilson, 304 F.2d 530, 3rd Cir. (1962)
United States v. Anthony J. J. A. Wilson, 304 F.2d 530, 3rd Cir. (1962)
2d 530
By the taxpayer's computation the statute resumed running May 11, 1954 and
expired in July 1957. Under the Government contention, the statute remained
suspended until its letter of April 18, 1956 which extended the statute to July 3,
1959. This suit against the taxpayer was commenced May 26, 1959 well within
the critical date according to the Government calculation.
We are satisfied therefore that the statute of limitations did not bar this suit
against the taxpayer. In view of this there is no need of our passing upon the
other point raised of whether the defendant was estopped from asserting the
statute of limitations defense.