Raleigh W. Hall & Margaret E. Hall v. United States

Tax Refund; Net Operating Losses; 26 U.S.C. § 172; Mitigation Provisions of 26 U.S.C. §§ 1311-1315; Circumstance of Adjustment, 26 U.S.C. § 1312

OPINION & ORDER

Futey, Judge.

This case is before the Court on defendant’s motion to dismiss for lack of subject matter jurisdiction, filed March 20, 2013. Plaintiffs responded on May 15, 2013 with a cross-motion for summary judgment, and defendant responded on June 6, 2013. Plaintiffs filed their reply on July 8, 2013. Defendant’s motion seeks dismissal of plaintiffs’ complaint on statute of limitations grounds, and plaintiffs seek summary judgment in…