J. Bradley Cohn and Elizabeth R. Cohn, on Behalf of Themselves and All Others Similarly Situated v. United States

J. Bradley Cohn and Elizabeth R. Cohn appeal from a judgment of the United States District Court for the Southern District of New York, John E. Sprizzo, Judge, awarding the government judgment on the pleadings and denying the Cohns’ motion for class certification. The Cohns dispute the manner in which the Internal Revenue Service (“IRS”) calculates interest on tax deficiencies. We affirm because the statutory language and legislative history of the relevant statute fully support the IRS’s position. We write only because the matter, while simple and straightforward, is apparently one of first…