Case: Pending Installment Agreement and Bankruptcy Proceedings Tolled Statute of Limitations; Carryback Defense Denied (D. Nev.)

The IRS was entitled to reduce federal income tax assessments to judgment against Taxpayer, held the district court, granting the IRS’s motion for summary judgment and denying Taxpayer’s cross-motions. Taxpayer, an individual who bought and sold water rights, self-reported owing $575,684 on his 2006 return but only paid $20,000. After the IRS assessed the reported amount plus penalties and interest in 2007, Taxpayer made payments totaling approximately $54,000, partially through wage garnishment, before filing for Chapter 11 bankruptcy in 2011. In 2020, the IRS filed suit to reduce the assessment to judgment. Taxpayer argued the suit was time-barred and attempted ...