Grossman v. United States

LINN, Circuit Judge.

William H. and Carolyn S. Grossman (“the Grossmans”) appeal from the United States Court of Federal Claims’ grant of summary judgment to the government on the Grossmans’ claim for a refund of taxes *357paid pursuant to a closing agreement with the Internal Revenue Service (“IRS”). Grossman v. United States, 57 Fed.Cl. 319 (2003). Because the Court of Federal Claims did not err in concluding that IRS Orders 209 and 12 are not in conflict with one another, we affirm.

BACKGROUND

The Grossmans entered into a closing agreement with the IRS in 1996 related to the tax treatment of…