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  5. 185 F.Supp.2d 1116 (2001)
 

U.S. v. STEPHENS

Nos. CIV.S-01-1076WBS/DAD, CIV.S-98-920WBS/DAD.

185 F.Supp.2d 1116 (2001)

UNITED STATES of America, Plaintiff, v. Lawrence H. STEPHENS, Defendant.

United States District Court, E.D. California.

December 10, 2001.

Attorney(s) appearing for the Case

G. Patrick Jennings, U.S. Dept. of Justice, Tax Div., Washington, DC, for plaintiff.

Andrew J. Weill, Law Offices of Andrew J. Weill, San Francisco, CA, for defendants.

MEMORANDUM AND ORDER

SHUBB, District Judge.

Plaintiff United States of America brought this lawsuit to reduce federal tax assessments against defendant Lawrence H. Stephens to judgment. Defendant moves for summary judgment on the grounds that the United States' claim is barred by the statutes of limitations in Sections 6502(a) and 6501(a) of the Internal Revenue Code. The United States brings a cross...

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