In a dispute involving a request for a tax refund, Court of Federal Claims' judgment is affirmed where the government's interpretation of the law is entitled to deference as its denial of plaintiff's refund claim on grounds that the assessment period under 26 U.S.C. sec. 6501 had expired was reasonable and not inconsistent with any prior interpretation that was entitled to deference.
Appeal from the United States Court of Federal Claims
Decided July 29, 2009
Before LINN, DYK, and PROST, Circuit Judges.
Opinion by PROST, Circuit Judge.
For Defendant: Francesca U. Tamami, United States Department of Justice, Washington, DC.