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UNITED STATES v. HARRIS TRUST AND SAVINGS BANK

No. 16299.

390 F.2d 285 (1968)

UNITED STATES of America, Plaintiff-Appellant, v. HARRIS TRUST AND SAVINGS BANK, Individually, as Executor of the Estate of Gertrude Witbeck Hanlin and as Trustee et al., Defendants-Appellees.

United States Court of Appeals Seventh Circuit.

Rehearing Denied March 11, 1968.

Attorney(s) appearing for the Case

Mitchell Rogovin, Lee A. Jackson, Crombie J. D. Garrett, Thomas H. Boerschinger, Dept. of Justice, Washington, D. C., Edward V. Hanrahan, U. S. Atty., Chicago, Ill., for appellant.

Clarence E. Fox, Paul S. Gerding, John J. Crown, Wilson & McIlvaine, Raymond, Mayer, Jenner & Block, Chicago, Ill., for appellees.

Before SWYGERT, FAIRCHILD and CUMMINGS, Circuit Judges.

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...

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