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ROCANOVA v. U.S.

No. 95 Civ. 8727(DC).

955 F.Supp. 27 (1996)

Mark ROCANOVA, Plaintiff, v. The UNITED STATES of America and Commissioner of the Internal Revenue of the United States of America, Defendants.

United States District Court, S.D. New York.

May 29, 1996.

Attorney(s) appearing for the Case

Mark Rocanova, New York City, pro se.

Mary Jo White, United States Attorney for the Southern District of New York by Linda A. Riffkin, Assistant U.S. Attorney, New York City, for Defendants.

MEMORANDUM DECISION

CHIN, District Judge.

In this action, plaintiff Mark Rocanova seeks a declaration that the retroactive application of § 11317(c) of Public Law 101-508, which revised § 6502 of the Internal Revenue Code by extending the statute of limitations for collection actions from six years to ten years, is unconstitutional. Rocanova bases this argument on the Due Process Clause of the Fifth Amendment, the Equal Protection Clause...

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