United States v. Vassallo, Inc., Eugene Vassallo, County of New Castle, Delaware, City of Wilmington, Delaware, Domenick Nardo, Intervenor

STALEY, Circuit Judge.

The primary question presented by this appeal is whether the appellantintervenor, a transferee of the taxpayer, was bound by taxpayer’s execution of Tax Collection Waiver-Form 900, extending the assessment and collection period for corporate taxes beyond the original six-year period of limitations.

This action arose out of the efforts of the government, for at least the last decade, to collect individual and corporate income taxes from Eugene and Georgie Vassallo and Vassallo, Inc. Eugene Vassallo, individually and as sole shareholder and controlling officer of Vassallo,…