Road & Highway Builders, LLC v. United States

LOURIE, Circuit Judge.

Plaintiff-Appellant Road and Highway Builders, LLC (“RHB”) appeals from a judgment of the United States Court of Federal Claims holding that RHB failed to meet its burden of proof that the United States Internal Revenue Service (“IRS”) acted in bad faith when it entered into a release to redeem certain real property. See Rd. & Highway Builders, LLC v. United States, 102 Fed.Cl. 88 (2011). Because RHB failed to rebut the presumption that the IRS agents discharged their duties in good faith by clear and convincing evidence, we affirm the entry of judgment against RHB.

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