Ramirez v. United States

In this suit for refund of Federal income tax,1 plaintiff (hereinafter “taxpayer”) contends that the 'government’s assessment of a deficiency in 'his income tax for 1961 was barred by the statute of limitations. The record does not specifically address the merits of the tax assessed, nor is there any controversy as to the amount of the tax collected. Hence, our consideration is limited solely to the question of whether the assessment was made in a timely fashion. For reasons enunciated below, we hold that it was.

The material facts are not in dispute. On December 12, 1970, taxpayer agreed in…