Legal Opinion

United States v. Potemken

Court of Appeals for the Fourth Circuit

Decided March 8, 1988No. 87-1616PublishedCited by 16 opinions

1Opinion of the Court

JAMES DICKSON PHILLIPS, Circuit Judge:

The United States appeals from the district court’s dismissal, on March 4, 1987, of its suit to foreclose federal tax liens imposed upon certain properties includable in the gross estate of Armstead Wayson who died on August 23,1974. The district court held that the special federal estate tax lien provided for in § 6324(a)(1) of the Internal Revenue Code of 1954, 26 U.S.C. § 6324(a)(1), has an absolute duration of ten years from the decedent’s death, which period is not tolled by the government’s filing of this foreclosure action. Because the lien had…

2Cases cited8 opinions

  1. Ernst & Ernst v. HochfelderSupreme Court of the United States · 1976
  2. Blue Chip Stamps v. Manor Drug StoresSupreme Court of the United States · 1975
  3. Tennessee Valley Authority v. HillSupreme Court of the United States · 1978
  4. Rubin v. United StatesSupreme Court of the United States · 1981
  5. In the Matter of Jerry Wolman and Anne Wolman, Debtors. Jerry Wolman and Anne Wolman v. Leonard H. ToseCourt of Appeals for the Fourth Circuit · 1972

3 more not listed; retrieve them via the Exa API.

3Cited by16 opinions

  1. United States v. BotefuhrCourt of Appeals for the Tenth Circuit · 2002
  2. Ronald James, and Kay James v. United StatesCourt of Appeals for the Tenth Circuit · 1992
  3. Amanda York Beaty and Nancie York Gunter v. United StatesCourt of Appeals for the Sixth Circuit · 1991
  4. United States v. Warren B. Davis, Trustee of the Warren B. Davis Revocable Living Trust, and Westwood Industrial Park, Ltd.Court of Appeals for the Eighth Circuit · 1995
  5. Smith-Berch, Inc. v. Baltimore County, Md.District Court, D. Maryland · 1999

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