In 1998, Anthony Saccullo executed and recorded a deed conveying Florida property to an irrevocable trust for his son, but the deed lacked one of the two witness signatures required by Florida law. After Anthony died, the United States assessed estate tax on the theory that the property remained in his estate and sought to foreclose federal tax liens. The district court granted summary judgment to the government. A Florida curative statute provides that, after five years, a recorded deed with a missing witness is treated as having its intended effect, absent specified exceptions. The Eleventh Circuit held that the statute operates automatically and cured the deed in 2003, two years before Anthony’s death. The federal estate-tax claim therefore had not accrued while the property was still in the estate. The court rejected the government’s reliance on the federal Summerlin principle, which prevents state limitations rules from extinguishing an already-accrued federal claim. Because the property had already passed to the trust before the federal claim could arise, the statute did not cut off an existing government right.