United States v. Johnson

MURPHY, Circuit Judge.

I. Introduction

The three consolidated appeals currently before this court involve an action brought by the Government to collect unpaid federal estate taxes. In Appeal No. 17-4083, the Government appeals from the district court's determination that its state-law contract claim was time-barred because it was subject to a Utah state six-year state statute of limitations. Exercising jurisdiction under 28 U.S.C. § 1291 , we conclude the state-law claim is governed by the ten-year statute of limitations set out in 26 U.S.C. § 6502 (a) because the Government is proceeding in…