Abbott Laboratories v. United States
Court of Appeals for the Federal Circuit
1Opinion of the Court
PROST, Circuit Judge.
Appellant Abbott Laboratories (“Abbott”) appeals from the dismissal of its suit in the United States Court of Federal Claims. Abbott Labs. v. United States, 84 Fed.Cl. 96 (2008). For the reasons set forth below, we affirm.
BACKGROUND
Generally, the government must assess any taxes owed within three years of the date the taxpayer filed its return. 26 U.S.C. § 6501(a). However, 26 U.S.C. § 6501(c)(4) permits the government and the taxpayer to agree to an extension of the assessment period. If the government receives the benefit of additional time in which to assess any taxes…
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