United States v. Newman

OPINION AND FINAL SUMMARY JUDGMENT

FULTON, Chief Judge.

This is an action by the Government, which seeks to reduce to judgment certain assessed income tax claims, against the Defendant, Joel Newman. Both sides have moved for summary judgment. All of the facts have been agreed to and are the subject of a pre-trial stipulation entered into on September 30, 1966 and filed in this cause. Thus there is no genuine issue of material fact. The *541only question is one of law, namely whether this action was timely filed, The result depends upon the construetion to be given to certain waivers of the statute…