Martin v. United States

OPINION

DAMICH, Judge:

Pending in this AMCOR tax case is Plaintiffs’ motion for reconsideration, filed August 5, 2011, regarding certain limitations and penalty interest claims. In their motion, Plaintiffs first question whether these claims were reinstated when final judgment against them was vacated on July 1, 2008. If their claims were not reinstated, they question whether the decision in the test case on these claims, Prati v. United States, 81 Fed.Cl. 422 (2008) (“Prati I”), constitutes the law of the case in their ease. Even if their claims were dismissed based on the decisions in Prati,…