No. 88-1214.

877 F.2d 965 (1989)

Herbert M. GANNET and Ruth Gannet, Plaintiffs-Appellants, v. The UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

June 15, 1989.

Attorney(s) appearing for the Case

Herbert M. Gannet, Newark, N.J., pro se.

William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen, William S. Estabrook and Kevin M. Brown, of Dept. of Justice, Washington, D.C., submitted for defendant-appellee.

Emily A. Parker and Mary J. Claiday, Thompson & Knight, Dallas, Tex., were on the brief for amicus curiae, Chevron Corp.

Before ARCHER and MICHEL, Circuit Judges, and SKELTON, Senior Circuit Judge.

ARCHER, Circuit Judge.

This appeal is from the United States Claims Court, No. 476-86 T, in which the cross motion of the United States (government) for summary judgment was granted, the motion by appellants, Herbert M. Gannet and Ruth Gannet (Gannet), for summary judgment was denied, and Gannet's complaint was dismissed. We affirm.


On September 4, 1985, Gannet filed amended federal income tax returns for the years 1978, 1979, 1980 and 1981, reflecting...

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