Arturo Fernandez and Inversal Administracion E Inversiones Limited, a Colombian Limited Partnership v. United States

This is an action to determine the reasonableness of a termination assessment under IRC § 7429(b). Upon motion by the government, the, district court dismissed the action as time barred. We affirm.

On August 3, 1981, the Internal Revenue Service (IRS) made a termination assessment under IRC § 6851 against the appellant, Arturo Fernandez. The termination assessment was for the taxable year January 1, 1981, to July 28, 1981, for $2,848,181. Upon notification, Fernandez was advised that a suit challenging the reasonableness of the termination assessment “must be filed within thirty days after the…