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Because petitioner did not file his tax returns for the years in
issue until October 18, 1995, respondent maintains that the
notice of deficiency, mailed July 9, 1998, was timely issued.
We have little difficulty concluding that the Federal
statute of limitations set forth in section 6501(a) overrides the
State statute cited by petitioner. Our holding on this point
finds support in both constitutional principles and Federal
policy considerations.
We begin our analysis with the so-called Supremacy Clause
contained in the U.S. Constitution, art. VI, cl. 2. The
Supremacy Clause states: "This Constitution, and the Laws of the
United States which shall be made in Pursuance thereof * * *,
shall be the supreme Law of the Land; and the Judges in every
State shall be bound thereby, any Thing in the Constitution or
Laws of any State to the Contrary notwithstanding." Consistent
with this constitutional principle, "it is well established that
federal claims are subject to state statutes of limitations
unless there is a federal statute of limitations or a conflict
with federal policy." South Carolina v. Catawba Indian Tribe,
Inc., 476 U.S. 498, 507 (1986). Further, where Congress
"explicitly puts a limit upon the time for enforcing a right
which it created, there is an end of the matter. The
Congressional statute of limitation is definitive." Holmberg v.
Armbrecht, 327 U.S. 392, 395 (1946); see Teamsters Pension Trust
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