United States Federal Circuit
Larosa's Int'l Fuel Co., Inc. v. US, 2007-5017
A judgment dismissing plaintiffs-taxpayers' consolidated tax refund suits is affirmed as neither the IRS's levies on taxpayers' funds nor the placement of taxpayers' funds in an escrow account constituted the payment of taxpayers' tax liabilities so as to stop the accrual of interest under I.R.C. section 6601(a).
Appellate Information
- Decided 09/18/2007
- Published 09/18/2007
Judges
- SCHALL, Circuit Judge., Before RADER, SCHALL, and LINN, Circuit Judges.
Court
- United States Federal Circuit
Counsel
- For Appellant:
- Thomas F. DeCaro, Jr., DeCaro & Howell, P.C., of Upper Marlboro, MD, argued for plaintiffs-appellants.
- 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 was Eileen J. O'Connor, Assistant Attorney General.