§11317

statute of limitations on collection. In that year, Congress amended section 6502(a)(1) to extend the period of limitations for the collection of taxes after assessment to 10 years. Omnibus Budget Reconciliation Act of 1990 (OBRA), Pub. L. 101-508, sec. 11317(a), 104 Stat. 1388-458. The 10-year limitations period applies to taxes assessed after November 5, 1990, and to taxes assessed on or before that date if the 6-year limitations period under prior law had not expired as of that date. Id. sub

the statute of limitations on collection under section 6502 was amended to provide a 10-year period from the date of assessment for the collection of Federal taxes (extended from 6 years). Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, sec. 11317(a)(1), 104 Stat. 1388-458. On May 19, 1995, the United States brought an action in the District Court for the Northern District of Oklahoma to reduce to judgment respondent's above $472,532 unpaid Federal income tax assessment against peti

1990) was suspended and remains 4 In 1990, Congress amended sec. 6502(a)(1) to extend the period of limitations for the collection of taxes after assessment from 6 years to 10 years. Omnibus Budget Reconciliation Act of 1990 (OBRA), Pub. L. 101-508, sec. 11317(.a), 104 Stat. 1388-458. The 10-year limitations period applies to taxes assessed after Nov. 5, 1990, and to taxes assessed on or before that date if the 6-year limitations period under prior law had not expired as of that date. Id. subsec

s stayed for more than 4 years while Mr. Johnson was in bankruptcy. See sec. 6503(h). Further, Congress extended the collection statute of limitations from 6 years to 10 years in 1990. See Ominibus Budget Reconciliation Act of 1990, Pub. L. 101-508, sec. 11317(b) and (c), 104 Stat. 1388, 1388-458 (1990)(with retroactive effect for taxes assessed on or before Nov. 5, 1990, if the collection statute was otherwise still open). - 11 - imposed by section 3713(b), which interest began to accrue as of