Gingerich v. United States

GAJARSA, Circuit Judge.

Fenton and Eunice Gingerich, Seung and Young Ho Karl, Choong and Joung Kim, Eugene Rosol, Charles Scruggs, Dae-Sob and Moon Yoon, Albert and Dorothy Liebovich, Carl and Nellie Liebovich, Gregory and Gail Liebovich, Joe and Belle Liebovich, Larry and Barbara Liebovich, and Samuel and Erna Liebovich (collectively the “Appellants” or “Taxpayers”) appeal from the Court of Federal Claims’ decision on summary judgment that the Internal Revenue Service (“IRS”) timely assessed the Taxpayers. Gingerich v. United States, 54 Fed. Cl. 222 (2002). Because there exist genuine…