Grossman v. United States

OPINION

ALLEGRA, Judge.

In this refund suit, pending before the court on cross-motions for summary judgment, one of the plaintiffs voluntarily agreed with the Internal Revenue Service (IRS) to resolve his tax liabilities, thereby avoiding the assertion, inter alia, of certain penalties and other additions to tax. Years later, after the statute of limitations on making new assessments for the tax years in question had run, that same taxpayer filed the instant suit with his wife, contending that the prior agreement was signed by the wrong IRS official and is void. As a result, plaintiffs assert,…