- 32 -
Petitioners contend that the Florida statututory period of
limitations on fraudulent conveyances precludes respondent from
asserting transferee liability here. We disagree. The
Commissioner is bound by Federal rather than State statututory
periods of limitations. United States v. Summerlin, 310 U.S.
414, 416 (1940); United States v. Fernon, 640 F.2d at 612 (U.S.
Government sought to collect tax by applying Florida fraudulent
conveyance law).
To reflect the foregoing and concessions,
Decisions will be
entered under Rule 155.
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Last modified: May 25, 2011