United States v. Estate of Albert Chicorel

McKEAGUE, Circuit Judge.

The government seeks to collect taxes owed by decedent Albert Chicorel. The government initially attempted to do so by filing a proof of claim in Chicorel's probate proceedings. That, however, yielded no results for over seven years, so the government commenced this action. Chicorel argues that the statute of limitations set in 26 U.S.C. § 6502 (a) bars this action. Finding that the government satisfied the statute of limitations by filing the proof of claim in the probate proceedings, we AFFIRM the district court's grant of summary judgment in favor of the government.

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