Court of Appeals for the Third Circuit January 29, 2003, 01-2132 (In Re: Roger Pransky, Debtor Internal Revenue Service v. Roger Pransky)

OPINION OF THE COURT

AMBRO, Circuit Judge.

Roger Pransky appeals the District Court’s determination that he failed to initiate in a timely manner this adversary proceeding against the Internal Revenue Service, as required to invoke the Bankruptcy Court’s jurisdiction pursuant to 26 U.S.C. § 6532(a)(1).