Liane B. Foutz v. United States

LOGAN, Circuit Judge.

Taxpayer Liane B. Foutz appeals the district court’s judgment granting the United States summary judgment in her income tax refund suit. The sole issue on appeal is whether the district court erred in finding that 1990 amendments to the statute of limitations on collections, I.R.C. § 6502, extended the limitations period for collection of the assessment against taxpayer in the circumstances of this case.

I

The facts are fully set out in the district court’s published decision, Foutz v. United States, 860 F.Supp. 788 (D.Utah 1994); we recite here only those necessary for our…