United States Federal Circuit

In a case involving a claim for interest netting under section 6621(d) of the Internal Revenue Code, summary judgment for the government is affirmed where the statute of limitations for plaintiff's 1983 tax year expired before July 22, 1998.

Appellate Information

• Decided 11/13/2006
• Published 11/13/2006

Judges

• DYK, Circuit Judge., Before MICHEL, Chief Judge, DYK and PROST, Circuit Judges.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Alan I. Horowitz, Miller & Chevalier, Chartered, of Washington, DC, argued for plaintiff-appellant.   With him on the brief were Thomas D. Johnston and Laurie A. Barber.


• For Appellees:
  
• Ellen Page Delsole, Attorney, Tax Division, 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, Richard T. Morrison, Deputy Assistant Attorney General, and Richard Farber, Attorney.