Mac Rohde, A/K/A Max Ralph Rohde, A/K/A Mack Rohde v. United States

HUFSTEDLER, Circuit Judge:

The District Court granted a summary judgment for the Government in this action to foreclose tax liens and to recover taxes assessed on June 8, 1956. The sole question on the taxpayer’s appeal is: Was the taxpayer’s waiver of the 6-year statute of limitations effective without the signature of the District Director upon the waiver, under the provisions of Section 6502(a) of the Internal Revenue Code of 1954?

Section 6502(a) provides that a proceeding for collection of federal taxes must be “begun — (1) within 6 years after the assessment of the tax, or (2) prior to…