LOURIE, Circuit Judge.
John A. Greene, receiver for the Great Global Assurance Company (GGAC), appeals from the decision of the United States Court of Federal Claims that dismissed his tax refund claim on the ground that the statute of limitations had run. See Green v. United States, 42 Fed. Cl. 18 (1998). Because we conclude that the trial court misconstrued the statute, we reverse.
BACKGROUND
During the 1983 taxable year, GGAC was a life...
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