United States v. Morris Weintraub

*614CELEBREZZE, Circuit Judge.

This appeal concerns the rule nullum tempus occurrit regi — the sovereign is exempt from the consequences of laches and the operation of statutes of limitations. The rule is of ancient origin and, while its original rationale of royal prerogative no longer holds sway, the maxim remains vital based upon the public policy of preserving public rights and revenues from the neglect of public officers. This principle causes us to affirm a civil tax judgment in favor of the United States in the face of an argument that the action was time-barred.

I

The facts involved in this…