DECISION and ORDER LESLIE G. FOSCHIO, Magistrate Judge. In this tax refund action, Plaintiffs claimed a refund of $419,924 for Plaintiffs’ 2002 tax year and $1,029,402 for Plaintiffs’ 2003 tax year (“the tax years”) based on Plaintiffs’ assertion of a …

DECISION AND ENTRY SHARON L. OVINGTON, Magistrate Judge. I. INTRODUCTION “The research tax credit is one of the most complicated provisions in the Code.” Suder v. Comm’r, T.C. Memo. 2014-201, 108 T.C.M. (CCH) 354, 2014 WL 4920724, at *77 (T.C. …

OPINION and ORDER CAMPBELL-SMITH, Chief Judge This is a tax refund case. Dynetics, Inc. (Dynetics or plaintiff) is an engineering company headquartered in Huntsville, Alabama. Plaintiff filed amended tax returns for three tax periods seeking a refund based on certain …

MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge. In this collection due process (CDP) case, petitioner seeks review pursuant to section 6330(d)(1)1 of the determination by the Internal Revenue Service (IRS or respondent) to uphold a notice of intent to …

WILSON, Circuit Judge: Plaintiff-appellant Geosyntec Consultants, Inc. (Geosyntec) appeals the district court’s grant of summary judgment in favor of defendant-appellee United States of America (United States) and against Geosyntec, in which the district court found that Geosyntec was not entitled …