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evade paying taxes known to be owing for each of the taxable
years at issue, the limitations period is extended indefinitely
pursuant to section 6501(c)(1) for each such year. Accordingly,
respondent is sustained on this issue.
Laches
Petitioner alternatively argues that the equitable doctrine
of laches operates to preclude respondent's assessment and
collection of the deficiencies in and additions to tax at issue
in the instant case. Respondent disagrees and contends that the
doctrine of laches must yield to the indefinite limitations
period imposed by section 6501(c)(1).
The doctrine of laches prohibits a party from asserting a
claim following an unreasonable delay by such party when there
has been a change in circumstances during such delay which would
result in severe prejudice against an opposing party should the
claim be permitted. See Albertson v. T.J. Stevenson & Co., 749
F.2d 223, 233 (5th Cir. 1984). It is well settled that the
United States is not subject to the defense of laches in
enforcing its rights. Guaranty Trust Co. v. United States, 304
U.S. 126, (1938); United States v. Thompson, 98 U.S. 486 (1878).
"[L]aches may not be asserted against the United States when it
is acting in its sovereign capacity to enforce a public right or
protect the public interest". United States v. Popovich, 820
F.2d 134, 136 (5th Cir.). The timeliness of Government claims is
governed by the statute of limitations enacted by Congress. See
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