- 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.”
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