Affirmed by published opinion. Judge NIEMEYER wrote the majority opinion, in which Chief Judge WILKINSON joined. Judge WIDENER wrote a dissenting opinion.
OPINION
NIEMEYER, Circuit Judge:
Section 6532(a) of the Internal Revenue Code requires a taxpayer who wishes to file a tax refund suit against the United States to do so within two years after the taxpayer is mailed formal notice of disallowance of the claimed refund or, if the taxpayer waives...
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