Legal Opinion
First Alabama Bank, N.A. v. United States
District Court, S.D. Alabama
Decided July 26, 1991No. Civ. A. 89-0141-B, 89-0142-BPublishedCited by 4 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
BUTLER, District Judge.
This matter came before the Court for an evidentiary hearing on the defendant’s motion to dismiss for lack of subject matter jurisdiction. These consolidated actions involve claims for recovery of federal estate taxes paid by the Estate of Bruce Cogle and for the recovery of federal estate and gift taxes paid by the Estate of Rosa Co-gle. The government contends that because these actions were not timely filed they are barred by the statute of limitations and, therefore, this Court has no subject matter jurisdiction over these actions. For…
2Cases cited18 opinions
- Irwin v. Department of Veterans AffairsSupreme Court of the United States · 1991
- Feres v. United StatesSupreme Court of the United States · 1950
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
- Lehman v. NakshianSupreme Court of the United States · 1981
- Schweiker v. HansenSupreme Court of the United States · 1981
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3Cited by4 opinions
- First Alabama Bank, N.A. v. United StatesCourt of Appeals for the Eleventh Circuit · 1993
- Finkelstein v. United StatesDistrict Court, D. New Jersey · 1996
- First Alabama Bank, N.A., Bruce A. Cogle, Jr., Jane C. Hamilton, Co-Executors of the Estate of Bruce A. Cogle, Sr., Deceased v. United States of America, First Alabama Bank, N.A., Bruce A. Cogle, Jr., Jane C. Hamilton, Co-Executors of the Estate of Rosa L. Cogle, Deceased v. United StatesCourt of Appeals for the First Circuit · 1993
- Hall v. United StatesDistrict Court, M.D. Tennessee · 1992