Abbott v. Arkansas Utilities Co‪.‬

The question is whether the six-year limitation fixed by 26 U.S.C.A. Int. Rev. Code, § 276(c), 53 Stat. 87, for bringing suits to collect income taxes after their assessment, is controlling of an action by the United States to recover on a contract between a third party and a taxpayer in which the third party, subsequent to a determination by the Commissioner of income tax deficiencies against the taxpayer and a redetermination by the Board of Tax Appeals (now the Tax Court), "assumes and agrees also to pay all of the personal and individual debts and liabilities of [the taxpayer] now existing".