The statute of limitations did not bar the government’s suit to reduce assessments to judgment. The ten-year statute of limitations on collection was extended for the period the taxpayer was in bankruptcy and for six months thereafter. Consequently, the ten-year period did not expire until ten days after the government filed its suit to reduce the assessments to judgment.

IRS collection actions against an individual were timely because the statute of limitations had not run on its ability to pursue the collection of unpaid taxes. The interaction of the amendments relating to offers in compromise made to Code Sec. 6502 by the Internal Revenue Service Restructuring and Reform Act of 1998 (P.L. 105-206), the Community Renewal Tax Relief Act of 2000 (P.L. 106-554) and the Job Creation and Worker Assistance Act of 2002 (P.L. 107-147) did not cause the collection action to be untimely. Also, the doctrine of laches did not bar the enforcement of government tax claims.

A married couple did not have a meritorious defense against the government’s claim relating to their tax liability. The husband’s tax liability was not negated by the government’s late filing of its suit to collect taxes because the government filed its complaint within the 10-year limitations period set forth in Code Sec. 6502(a).

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