United States v. Warren B. Davis, Trustee of the Warren B. Davis Revocable Living Trust, and Westwood Industrial Park, Ltd.

MORRIS SHEPPARD ARNOLD, Circuit Judge.

This appeal requires us to visit a narrow question: whether the 10-year period set forth in the estate tax lien statute, 26 U.S.C. § 6324(a)(1), is durational or limitational. If the period is durational, the government has ten years to enforce the lien before it expires. If the period is limitational, the government has ten years to file its complaint. After reviewing the statute and the cases that have considered the issue before us, we conclude that the ten-year period is durational and dismiss the appeal as moot.

I

The government commenced this suit on…