Dimitrious J. Lignos and Evelyn Lignos v. United States

FEINBERG, Circuit Judge:

In this case taxpayers are seeking to apply in reverse Mr. Justice Holmes’s famous advice that men dealing with the Government must turn square corners. 1 Plaintiffs Dimitrious J. and Evelyn Lignos appeal from an order of the United States District Court for the Western District of New York, John O. Henderson, Chief Judge, which granted summary judgment to the United States in plaintiffs’ suit for a tax refund. The basis of the judgment was that plaintiffs were equitably estopped from bringing their claim. For reasons set forth below, we believe that there are genuine…