United States v. Cook

CARL O. BUE, Jr., District Judge.

The sole question raised by defendant’s Motion for Summary Judgment in the instant case concerns the point in time at which the waiver agreement filed pursuant to an offer in compromise submitted by taxpayer to the Internal Revenue Service becomes effective; that is, for what period of time is the statute of limitations tolled.

Section 6502(a) of the Internal Revenue Code of 1954 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 the expiration of any period for…