American Guardian Holdings, Inc. v. United States

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION AMERICAN GUARDIAN HOLDINGS, ) INC., ) ) Plaintiff, ) ) vs. ) Case No. 23 C 1482 ) UNITED STATES OF AMERICA, ) ) Defendant. ) MEMORANDUM OPINION AND ORDER MATTHEW F. KENNELLY, District Judge: American Guardian Holdings Inc. (AGH) has sued the United States to recover what it contends are overpaid income taxes. The government has moved to dismiss for lack of subject matter jurisdiction. It contends that AGH did not file a timely claim for a refund before filing suit and that even if it did, the lawsuit…