United States v. Joseph H. Hans

RYAN, Circuit Judge.

In this action to reduce to judgment federal income tax assessments made against taxpayer Joseph H. Hans, the district court denied in part the government’s motion for summary judgment against taxpayer Hans, on the ground that the statute of limitations had run with respect to one of the government’s claims.

The issue on appeal is whether a decision of the tax court becomes “final” within the meaning of I.R.C. § 6503(a) on 1) the date the decision is entered, or 2) the last date that the taxpayer could notice a timely appeal from the decision. We hold that a tax court…