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U.S. v. SILVERMAN

No. 82-6106.

859 F.2d 1352 (1988)

UNITED STATES of America, Plaintiff-Appellee, v. Dorothy SILVERMAN, Administratrix, Estate of Fred R. Silverman, Deceased, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided October 13, 1988.

Attorney(s) appearing for the Case

A.V. Falcone, Los Angeles, Cal., for defendant-appellant.

Roger M. Olsen, Acting Asst. Atty. Gen. Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Michael L. Paup, William S. Estabrook, Martha Brissette, Attorneys, Tax Div., Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Before ALARCON and POOLE, Circuit Judges and SCHWARZER, District Judge.

PER CURIAM:

This is the second appeal arising out of the government's efforts to collect the unpaid balance of an assessment of federal estate taxes against the estate of Fred R. Silverman, who died in 1963. In the prior appeal, we held that 26 U.S.C. § 6503(b) suspended the running of the statute of limitations so long as all or substantially all of the assets of the decedent were subject to the control or custody of the probate court. United States v. Silverman...

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