United States First Circuit

In a suit to recover alleged income tax overpayments, summary judgment for the government is affirmed where the language of Tax Court judgments that embodied a settlement agreement between the parties unambiguously favored the government's interpretation, and the district court did not err by failing to consider extrinsic evidence.

Appellate Information

• Decided 02/15/2008
• Published 02/15/2008

Judges

• STAHL, Senior Circuit Judge., Before TORRUELLA and LYNCH, Circuit Judges, and STAHL, Senior Circuit Judge.

Court

• United States First Circuit

Counsel

• For Appellant:
  
• Robert R. Lucic with whom Peter T. Beach, Courtney H.G. Herz, and Sheehan Phinney Bass & Green, P.A., were on brief for appellant.


• For Appellees:
  
• Deborah K. Snyder with whom Richard T. Morrison, Acting Assistant Attorney General, Gilbert S. Rothenberg, Acting Deputy Assistant Attorney General, and Kenneth L. Greene were on brief for appellee.