Legal Opinion

Zhou v. United States

United States Court of Federal Claims

Decided August 16, 2017No. 16-884TPublishedCited by 3 opinions

1Opinion of the Court

OPINION AND ORDER

WHEELER, Judge.

Plaintiffs Jianglin Zhou and Jie Shen seek the return of funds levied by the Internal Revenue Service (“IRS”) to cover their alleged underpayment of 2006 and 2007 tax liability. The Plaintiffs claim that them tax liability for 2006 and 2007 was completely resolved by a previous Tax Court decision. The Government argues that the Tax Coiirt decision only resolved Plaintiffs’ deficiency for 2006 and 2007, but not their underpayment of tax liability, and the IRS properly levied the Plaintiffs’ property. The Court GRANTS the Government’s motion for summary judgment…

2Cases cited11 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  3. Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
  4. Brown-Forman Distillers Corp. v. New York State Liquor AuthoritySupreme Court of the United States · 1986
  5. Gerald Alan Brown, and Charles v. Darnell v. United StatesCourt of Appeals for the Federal Circuit · 1997

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3Cited by3 opinions

  1. Beres v. United StatesUnited States Court of Federal Claims · 2019
  2. Metzinger v. United StatesUnited States Court of Federal Claims · 2025
  3. Zhou v. United StatesCourt of Appeals for the Federal Circuit · 2018

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