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AMEEL v. UNITED STATES

No. 19983.

426 F.2d 1270 (1970)

Francis H. AMEEL, Administrator d.b.n. Estate of Mary E. Ameel, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

June 3, 1970.

Attorney(s) appearing for the Case

J. Leon Katz, Detroit, Mich., for appellant.

Richard Farber, Dept. of Justice, Washington, D. C., (Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, William A. Friedlander, Attys., Dept. of Justice, Washington, D. C., on the brief), for appellee. James H. Brickley, U. S. Atty., Detroit, Mich., of counsel.

Before CELEBREZZE and COMBS, Circuit Judges, and O'SULLIVAN, Senior Circuit Judge.

CELEBREZZE, Circuit Judge.

This is an appeal from a judgment of the United States District Court for the Eastern District of Michigan granting the Government's motion to dismiss for lack of jurisdiction over the subject matter. The Appellant seeks refund of federal estate taxes alleged to have been erroneously assessed and collected against the estate. Section 7422 of the Internal Revenue Code of 1954, 26 U.S.C. § 7422 (1964). The District Court granted Appellee...

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