Singleton v. United States

*705 ORDER

BRITT, District Judge.

Before the court are the parties’ cross-motions for summary judgment. A hearing was held before the undersigned on 21 March 1996. The issues have been fully briefed and addressed, and this matter is thus ripe for disposition.

I. FACTS

In August 1988, plaintiffs filed their income tax return for the tax year 1987. On such return, plaintiffs claimed the following:

Total tax due $160,370

Total tax payments $190,661

Refund claimed due $ 30,291

In October 1988, the Internal Revenue Service (“IRS”) issued plaintiffs a “Correction Notice-Refund Due Taxpayer,” therein notifying…