Robert M. St. John, Margaret E. St. John v. United States of America, Robert M. St. John, Margaret E. St. John v. United States

The government appeals the district court’s order denying its motion for judgment notwithstanding the verdict. It argues the district court erred in holding the government must assess a deficiency in a taxpayer’s tax within a reasonable period of time, and therefore in submitting to the jury an interrogatory asking whether the government had done so in the St. John’s case. Taxpayers cross-appeal, 1 claiming the jury erred in finding against them on two other interrogatories. 2

I

Internal Revenue Code § 6501(a) provides that taxes must be assessed within three years after the return is filed. An…