In re the Estate of Mayer

John D. Bennett, S.

In this accounting proceeding the sole beneficiary of the estate questions the validity of an allowed claim of the United States Government for income tax deficiencies and accrued interest assessed against the decedent and her late husband for the tax years 1945 and 1946.

During the hearing, the court ruled that it was the burden of the objectant to overcome the prima facie presumption of the validity of the allowed claim. The objectant, however, claimed that since the usual statutory period of limitations both as to the assessment and collection of the tax had expired, it…