United States v. Laura Giaimo

MELLOY, Circuit Judge.

Taxpayer Laura Giaimo appeals from the District Court’s 1 grant of summary judgment in favor of the United States in this action to reduce a tax lien to judgment and foreclose upon real property. Giaimo incurred substantial tax liabilities in the 1990s when she failed to properly handle taxes associated with a day-care business she operated. The sole question before our court is whether an underlying Tax Court appeal Giaimo filed in March 2006 served to toll the limitations period applicable to the government’s current collection efforts. It is undisputed that if tolling…