Jeffrey G. SHARP, Plaintiff-Appellee,
v.
The UNITED STATES, Defendant-Appellant.
United States Court of Appeals, Federal Circuit.https://leagle.com/images/logo.png
December 28, 1993.
December 28, 1993.
Attorney(s) appearing for the Case
Keith A. Jones, Fulbright & Jaworski, L.L.P., Washington, DC, argued for plaintiff-appellee. With him on the brief were Charles W. Hall, John R. Allender, and Ronald W. Adzgery, Fulbright & Jaworski, L.L.P., Houston, TX.
Gilbert Rothenberg, Atty., Dept. of Justice, Washington, DC, argued for defendant-appellant. With him on the brief were Michael L. Paup, Acting Asst. Atty. Gen., Gary R. Allen and Teresa T. Milton, Attys.
Before NEWMAN, LOURIE, and SCHALL, Circuit Judges.
United States Court of Appeals, Federal Circuit.
LOURIE, Circuit Judge.
The United States appeals from a decision of the United States Court of Federal Claims1 granting summary judgment in favor of taxpayer Jeffrey G. Sharp on his claim for a tax refund and denying the United States' cross-motion for summary judgment. Sharp v. United States, 27 Fed.Cl. 52 (Ct. Fed.Cl.1992). Because the Internal Revenue Code ("IRC" or "Code") in effect at the relevant time did not limit the carryover...
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