United States v. Supervised Estate of Breidenbaugh

OPINION

BAILEY, Judge.

Case Summary

Appellant United States of America, on behalf of the Internal Revenue Service, (collectively referred to as the "IRS") appeals the trial court's order disallowing a tax claim against the Supervised Estate of Arlo Breidenbaugh, Jr., ("Estate"). We reverse.

Issue

The IRS raises three issues on appeal, which we consolidate and restate as whether the trial court erred by disallowing the IRS's tax claim as being time-barred under both state and federal statutes of limitations.

Facts and Procedural History

The parties have stipulated to the following relevant facts. On…