United States Federal Circuit

The Court of Federal Claims' finding that the IRS properly offset statutory interest erroneously paid to plaintiff is reversed where the IRS made the offset after the statute of limitations under 26 U.S.C. section 6532(b).

Appellate Information

• Decided 08/10/2005
• Published 08/10/2005

Judges

• ARCHER, Senior Circuit Judge., Before MICHEL, Chief Judge,ARCHER, Senior Circuit Judge, and BRYSON, Circuit Judge.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Craig Martin Buchsbaum, Pacific Gas and Electric Company, of San Francisco, California, argued for plaintiffs-appellants.


• For Appellees:
  
• Andrea R. Tebbets, Attorney, Tax Division, Appellate Section, United States Department of Justice, of Washington, DC, argued for defendant-appellee.   With her on the brief were Eileen J. O'Connor, Assistant Attorney General and Richard Farber, Attorney.