The following excerpt is from U.S. v. Bacon, 82 F.3d 822 (9th Cir. 1996):
Because the state statute of limitations for actions under the Conveyance Act does not apply to the federal government, the applicable limitation is the ten-year federal statute of limitations governing tax assessment collection actions. 26 U.S.C. 6502(a)(1). United States v. Overman, 424 F.2d 1142, 1147 (9th Cir.1970); see also Fernon, 640 F.2d at 612 (ruling that government's collection action brought under Florida's fraudulent conveyance statute was governed by 26 U.S.C. 6502(a)(1)).
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