Larosa's International Fuel Co. v. United States

OPINION AND ORDER

WHEELER, Judge.1

These consolidated cases are before the Court on cross-motions for summary judgment on the Government’s counterclaim alleging that Plaintiffs owe additional interest for the 1979 tax year. At issue is whether Plaintiffs’ payment in satisfaction of certain Tax Court stipulations and an Internal Revenue Service (“IRS”) Form 906 closing agreement with the Government included interest. For the reasons explained below, the Court concludes that these agreements did include interest, and that Plaintiffs do not owe additional interest. The Court therefore GRANTS…