Pcce, Inc. v. United States of America Internal Revenue Service

PREGERSON, Circuit Judge:

Plaintiff-Appellant PCCE (“taxpayer” 1 ) challenges the government’s tax and interest assessments for tax years 1974 and 1978, as well as its tax liens. The Tax Court entered a stipulated judgment in which the parties agreed as to the amount taxpayer owed. The district court determined the assessments and liens to be valid.

On appeal taxpayer does not argue that the government assessed these tax and interest deficiencies too heavily. Instead, taxpayer complains that because the government assessed the deficiencies too soon under 26 U.S.C. § 6213(a), the assessments and…