Tax Law Update September 2012

• No equitable tolling of statutory period of limitations for tax refund suits—In Davis v. U.S., 110 A.F.T.R.2d 2012-5027 (June 28, 2012), the executor of the estate of Anthony Walker Smith sued for a refund of income taxes the estate had previously paid. The district court for the Northern District of Mississippi dismissed the case for lack of subject matter jurisdiction, and the U.S. Court of Appeals for the Fifth Circuit affirmed.