United States v. Harris Trust and Savings Bank, Individually, as of the Estate of Gertrude Witbeck Hanlin and as Trustee

CUMMINGS, Circuit Judge.

This appeal raises the question whether the Government’s suit to collect a federal estate tax assessment was barred by the statute of limitations. Gertrude Witbeck Hanlin died insolvent on April 11, 1952. In the following year, her Executor, Harris Trust and Savings Bank of Chicago, filed a federal estate tax return disclosing that she had an interest in a trust created by her grandfather. 1 This interest generated a claim for federal estate taxes, resulting in an August 23, 1956, assessment of $92,459.-63, plus interest, against Mrs. Hanlin’s estate.

On August 3, 1960,…