McManus v. United States

Tax Refund Suit; Summary Judgment; RCFC 56; U.S.-Ireland Tax Treaty

OPINION

FIRESTONE, Senior Judge.

Pending before the court in this tax refund ease are cross-motions for summary judgment pursuant to Rule 56 of the Rules of the Court of Federal Claims (“RCFC”) filed by plaintiff John P. McManus and defendant the United States (“the government”). Mr. Mc-Manus’s tax refund claim arises in connection with a three-day backgammon match that took place in the United States. Following the match, Mi*. McManus reported gambling winnings of $17,400,000 as “United States source income” for 2012. Pl.’s…