Donna Ebeyer and Glenn Ebeyer v. United States

OPINION

BUSH, Senior Judge.

Now pending before the court is defendant’s motion for summary judgment pursuant to Rule 56 of the Rules of the United States Court of Federal Claims (RCFC). Defendant’s motion has been fully briefed and is ripe for decision. Oral argument was neither requested by the parties nor required by the court. Because the court concludes that plaintiffs’ claim is time-barred under § 6511(b)(2)(A) of the Internal Revenue Code, 26 U.S.C. § 6511(b)(2)(A) (2012), defendant’s motion is granted. 1

BACKGROUND 2

Donna and Glenn Ebeyer 3 filed their 2006 joint federal income tax return…