Legal Opinion
Sandoval Lua v. United States
Court of Appeals for the Federal Circuit
Decided December 15, 2016No. 2016-1313PublishedCited by 6 opinions
1Opinion of the Court
Wallach, Circuit Judge.
Armando Sandoval Lua and Yadira Sandoval (together, “the Sandovals”) appeal from the decision of the U.S. Court of Federal Claims (“Claims Court”) granting summary judgment in favor of the United States (“Government”) as to certain tax refunds claimed by the Sandovals. See Sandoval Lua v. United States, 123 Fed. Cl. 269,277 (2015). We affirm.
Background
In 2006, the U.S. Internal Revenue Service (“IRS”) opened an audit of the Sando-vals’ tax return for the 2004 fiscal year. Appellee’s Suppl. App. (“SA”) 3. The IRS later expanded this audit to include the 2003 and 2005…
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