John M. Capozzi v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that section 2462 does not apply to the assessment of section 6700 penalties be- cause “an assessment is neither an action, a suit, nor a proceeding”
• “[T]hough section 6502(a) speaks only of the collection of taxes, 26 U.S.C. § 6671 states that any reference to a ‘tax’ is also a reference to a penalty.”

Source: CourtListener parenthetical corpus (CC0).