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could then be barred if untimely. See Guaranty Trust Co. v. United
States, 304 U.S. 126, 136 (1938). The preservation and protection
of public rights, revenues, and property from the negligence of
public officers deteriorates when exceptions are made for time
limitations that have the same purpose as statutes of limitations
but in a different form. And the extinguishment provision of the
UFTA was created precisely to circumvent the rule in United States
v. Summerlin, supra, a provision that the Court of Appeals for the
Ninth Circuit described as a "dressed-up statute of limitations".
United States v. Bacon, 82 F.3d at 824 n.2; see Dillman v.
Commissioner, 64 T.C. 797, 806 (1975) ("If the State statute
attempts to abrogate or void the existing claim of the United
States by use of a different timetable it will be attempting to
reach beyond its powers. By whatever name such a statute might be
called it would be in effect a statute of limitations not binding
on the United States."). While a State may limit the jurisdiction
of its own courts for private claimants, time limitations imposed
on the United States' efforts to collect its taxes would
"transgress the limits of state power." United States v.
Summerlin, supra at 417.
Federal revenue law requires national application that is not
displaced by variations in State law. Tax assessment and
collection against a transferee in transferee liability cases is a
difficult task; to complete such a task within arbitrary time
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