Paul L. Tregre, Jr. - Page 25

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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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