Christman v. United States

Tax; Refund Suit, 26 U.S.C. § 7422 (2006); Additions to Tax, 26 U.S.C. §§ 6651(a)(2), 6654 (2006); No Reasonable Cause, or Other Statutory Provision, to Excuse Taxpayers from Tax Penalties.

OPINION

Bush, Judge.

This case is before the court on cross-motions for summary judgment under Rule 56 of the Rules of the United States Court of Federal Claims (RCFC). These motions have been fully briefed, and oral argument was neither requested by the parties nor deemed necessary by the court. The disposi-tive issue before the court is whether the decision by the Internal Revenue Service (IRS) to grant…