STARKEY v. UNITED STATES

Civ. No. 85-3032.

635 F.Supp. 1007 (1986)

Bill W. STARKEY and Jean Starkey, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Arkansas, Harrison Division.

February 25, 1986.


Attorney(s) appearing for the Case

David L. Osmon, Mountain Home, Ark., for plaintiffs.

Michael N. Wilcove, Atty., Tax Div., Dept. of Justice, Washington, D.C., for defendant.


MEMORANDUM OPINION

H. FRANKLIN WATERS, Chief Judge.

Before the court is the motion of the United States to dismiss plaintiffs' cause of action on grounds that the suit was not filed within the two-year period prescribed by the statute of limitations. 26 U.S.C. § 6532. In reply, plaintiffs argue that the United States should be equitably estopped from pleading the statute by virtue of the following facts: (1) That in January, 1983, the Starkeys filed...

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