United States Third Circuit

Where an agreement between the IRS and a taxpayer that does not mention the amount of the refund or the method for refund calculation, the agreement's limited anti-retroactivity clause does not preclude retroactive application of amendments that exclude certain credits.

Appellate Information

• Argued 05/31/2001
• Decided 11/01/2001
• Published 11/01/2001

Judges

• Before:  SLOVITER, FUENTES and COWEN, Circuit Judges.

Court

• United States Third Circuit

Counsel

• For Appellant:
  
• Melvin E. Lefkowitz (Argued), Hogan & Hartson, Washington, DC, Attorney for Appellant.


• For Appellees:
  
• Charles Bricken (Argued), Richard Farber, United States Department of Justice, Washington, DC, Attorneys for Appellee.