Indiana National Corporation and Its Subsidiaries: Indiana National Bank v. United States

FLAUM, Circuit Judge.

Indiana National Corporation and its subsidiaries appeal from the dismissal of their claims for refund of federal corporate income taxes for the years 1967 and 1970. The district court dismissed the claims as untimely, rejecting the appellants’ arguments that a special seven year statute of limitations applied and, alternatively, that an agreement between the parties extended the limitations period. We affirm.

I

The plaintiffs are affiliated corporations that filed consolidated Form 1120 income tax returns with the Internal Revenue Service. They filed a refund claim for…