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U.S. Court of Appeals for the First Circuit, 1965

The First National Bank of Miami, as Successor of the Estate of John P. Cassidy, Deceased v. United States

The First National Bank of Miami, as Successor of the Estate of John P. Cassidy, Deceased v. United States
U.S. Court of Appeals for the First Circuit · Decided February 15, 1965 · Tuttle, Rives, Simpson
341 F.2d 737; 15 A.F.T.R.2d (RIA) 1316 (Federal Reporter, Second Series)

The First National Bank of Miami, as Successor of the Estate of John P. Cassidy, Deceased v. United States

Opinion

PER CURIAM.

It being undisputed that the claim for refund of gift taxes was not filed until more than three years following the filing of the return and more than two years following the payment of the tax, the trial court correctly held that the suit for refund must be dismissed as being barred by the applicable statute of limitations, 26 U.S.C.A. § 6511. The judgment is affirmed on the opinion of the District Court, 226 F.Supp. 166 (S.D.Fla. 1963).

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