United States v. Thomas W. Banks and Reta Banks A/K/A Reta L. Banks or Rita L. Banks

MEREDITH, Chief District Judge.

This is an appeal from a judgment entered against Thomas W. Banks and Reta Banks, his wife, on the basis of jeopardy assessments and a bond given by them to insure collection of taxes. Judgment was entered by the United States District Court for the District of Minnesota, on a motion for summary judgment, filed by the Government and on motions to dismiss filed by taxpayers. 1

The questions presented are: (1) whether the suspension provision of section 277 of the Internal Revenue Code of 1939 applies to the limitation provision of subsection (c) of section 276, so…