Larosa's Intern. Fuel Co., Inc. v. United States

SCHALL, Circuit Judge.

LaRosa’s International Fuel Co., Inc., (“LaRosa Fuel”) and Joseph LaRosa (together, “taxpayers”) appeal the final judgment of the United States Court of Federal Claims dismissing their consolidated tax refund suits. LaRosa’s Int’l Fuel Co. v. United States, Nos. 97-834T, 97-835T (Oct. 30, 2006). In their suits, taxpayers sought to recover interest they paid on unpaid taxes for the period while funds belonging to them were subject to Internal Revenue Service (“IRS”) levies and were held in an escrow account established by taxpayers and the IRS. On April 3, 2003, the court…