Allison v. United States

ORDER

BUNTON, Chief Judge.

BEFORE THIS COURT is the Defendant’s Motion for Summary Judgment and the Plaintiffs’ Cross Motion for Summary Judgment based on stipulated facts. Both the Defendant and the Plaintiffs have filed briefs in support and in opposition of Summary Judgment. After consideration of the arguments of all parties, along with applicable case law and statutory authority, the Court finds Defendant’s Motion for Summary Judgment contains merit and is GRANTED.

ISSUE

Whether the Plaintiffs are entitled to a refund of $261,196 of income tax paid on their 1984 income tax return, and any…