U.S. v. ESTATE OF CHICOREL

No. 17-2321.

907 F.3d 896 (2018)

UNITED STATES of America, Plaintiff-Appellee, v. ESTATE OF Albert CHICOREL; Richard Behar, as Personal Representative of the Estate of Albert Chicorel, Defendants-Appellants.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: October 25, 2018.


Attorney(s) appearing for the Case

ARGUED: Steven G. Cohen , COHEN & ASSOCIATES PC, Farmington Hills, Michigan, for Appellants. Richard Caldarone , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. ON BRIEF: Steven G. Cohen , COHEN & ASSOCIATES PC, Farmington Hills, Michigan, for Appellants. Richard Caldarone , Gilbert S. Rothenberg , Thomas J. Clark , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Before: GIBBONS, SUTTON, and McKEAGUE, Circuit Judges.


OPINION

The government seeks to collect taxes owed by decedent Albert Chicorel. The government initially attempted to do so by filing a proof of claim in Chicorel's probate proceedings. That, however, yielded no results for over seven years, so the government commenced this action. Chicorel argues that the statute...

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