United States Federal Circuit

In an action brought by taxpayers seeking a full refund from the IRS for overpayment, the U.S. Court of Federal grant of summary judgment in favor of the Government and denied a cross-motion for summary judgment, finding that as a matter of law the plaintiffs were not entitled to the claimed refunds.where the Claims Court properly granted summary judgment to the Government because: 1) plaintiffs consented to assessment without notice of deficiency; 2) the 2004 assessment limitations period had not expired; 3) the 2008 remittances were appropriately considered as tax payments; and 4) plaintiffs waived their additional arguments.

Appellate Information

• Published 2016/12/15

Judges

• WALLACH

Court

• United States Federal Circuit

Counsel