United States v. Steinbrenner

ORDER

STEVEN D. MERRYDAY, District Judge.

This is a dispute about a tax refund that the United States (more descriptively, the Internal Revenue Service or IRS) initially granted but now seeks to recover. The taxpayers move (Doc. 16) for summary judgment, and in response the IRS moves (Doc. 17) for summary judgment. Because the IRS concedes the taxpayers’ entitlement to the refund if the taxpayers’ demand was timely, a determination of the applicable statute of limitation resolves this action. But the considerations that identify the applicable limitation reside discretely among the forbidding…