Gisele C. FISHER, Plaintiff-Appellee,
v.
The UNITED STATES, Defendant-Appellant.
United States Court of Appeals, Federal Circuit.https://leagle.com/images/logo.png
April 10, 1996.
April 10, 1996.
Attorney(s) appearing for the Case
Paul W. Oden, Miller, Nash, Wiener, Hager & Carlsen, Seattle, Washington, argued for plaintiff-appellee.
Joan I. Oppenheimer, Attorney, Department of Justice, Washington, D.C., argued for defendant-appellant. With her on the brief were Loretta C. Argrett, Assistant Attorney General, Gary R. Allen and Jonathan S. Cohen, Attorneys.
Before LOURIE, Circuit Judge, FRIEDMAN, Senior Circuit Judge, and BRYSON, Circuit Judge.
United States Court of Appeals, Federal Circuit.
FRIEDMAN, Senior Circuit Judge.
In Lewis v. Reynolds,284 U.S. 281, 52 S.Ct. 145, 76 L.Ed. 293, modified on other grounds, 284 U.S. 599, 52 S.Ct. 264, 76 L.Ed. 514 (1932), the Supreme Court held that in a tax refund suit, the Internal Revenue Service (IRS) may offset against the refund other taxes that had previously not been assessed, and the assessment of which the statute of limitations barred. The question in this...
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