Jesse E. Hall, Sr. v. United States

GRIFFIN B. BELL, Circuit Judge.

This is an interlocutory appeal under 28 U.S.C.A. § 1292(b), from an order denying summary judgment. The focus of the litigation is an effort by the United States to collect taxes from transferees of original taxpayers, the transfers allegedly having been made to defraud the tax collector.

Appellant-transferees sought summary judgment on the ground that no tax had been assessed as to them and that the action was barred by the six-year statute of limitations imposed by § 6502 of the 1964 Internal Revenue Code. 26 U. S.C.A. § 6502. The sole issue presented to us is…