United States of America, Plaintiff/counter-Claim-Defendant/appellee v. Toyota of Visalia, Inc., Defendant/counter-Claimant/appellant

988 F.2d 126 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. UNITED STATES of America, Plaintiff/Counter-Claim-Defendant/Appellee, v. TOYOTA OF VISALIA, INC., Defendant/Counter-Claimant/Appellant. No. 91-16488. United States Court of Appeals, Ninth Circuit. Argued and Submitted Feb. 4, 1993. Decided Feb. 16, 1993. Appeal from the United States District Court for the Eastern District of California, No. CV-90-00171-REC; Robert E. Coyle, District Judge, Presiding. E.D. Cal., 772 F.Supp. 481 . AFFIRMED. Before FARRIS, POOLE and WIGGINS, Circuit Judges. 1 MEMORANDUM * OVERVIEW 2 Toyota of Visalia, Inc. appeals from the district court's summary judgment in favor of the United States in the government's action to reduce to judgment an assessment of interest made against Toyota's 1979 income tax liability. We affirm. DISCUSSION 1. Statute of Limitations 3 Toyota argues that the government's action is barred by the six-year statute of limitations contained in 26 U.S.C. § 6502…