- 6 - been final. See secs. 7481(a)(1), 7483. E. District Court Collection Suit In or about March 1996, the United States commenced a civil action against petitioner in the U.S. District Court for the Middle District of Alabama. The action, which sought to reduce the Government’s tax claims for 1980 through 1982 to judgment, prayed that the Court find the “defendant, Robert C. MacElvain, indebted to the United States in the amount of $2,091,477.76, as of March 18, 1996, for unpaid federal income tax liabilities for calendar years 1980, 1981, and 1982, plus further accruals of interest and statutory additions thereon according to law, and that judgment be entered in favor of plaintiff United States of America for that amount.” Petitioner participated actively in the foregoing action, asserting a variety of defenses, specifically including the statute of limitations. In April 1997, the District Court entered judgment in favor of the United States and against petitioner “for unpaid taxes, interest, penalties and lien fees for the years 1980, 1981 and 1982 * * * in the amount of $2,091,477.76 plus interest and statutory additions as allowed by law”.4 4 The District Court’s judgment made clear that the sum of $2,091,477.76 represented “the amount due and payable through March 18, 1996" and did not include “additional interest, penalties or fees which may have accrued since that time.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011