United States v. Giaimo, No. 16-2479 (8th Cir. 2017)Annotate this Case
Taxpayer appealed the district court's grant of summary judgment for the government in this action to reduce a tax lien to judgment and foreclose upon real property. The court concluded that an underlying Tax Court appeal taxpayer filed in March 2006 served to toll the limitations period applicable to the government's current collection efforts. The court explained that, in the unique circumstances of this extremely tardy challenge, taxpayer cannot rely upon the absence of evidence of a date of mailing to carry her own heavy burden to disprove the Tax Court's jurisdiction over her 2006 appeal. Accordingly, the court affirmed the judgment.