Your Insurance Needs Agency Inc. v. United States

PATRICK E. HIGGINBOTHAM, Circuit Judge:

David Bruce Earl and Your Insurance Needs Agency, Inc. appeal from a grant of summary judgment to the Government on their claims for refunds of over $77,000 in tax overpayments in 1991, 1992, 1993, and 1994, inclusive, brought under 26 U.S.C. § 7422(a). We affirm.

I

In 1991, Earl, the sole officer and shareholder of Your Insurance, hired David Shand, a certified public accountant, to prepare and file Your Insurance’s and his own federal tax returns. Pursuant to Earl’s instructions and authorization, Shand prepared and submitted individual income tax…