MICHEL, Circuit Judge.
This is a consolidated appeal from four summary judgments of the United States Court of Federal Claims. See Olson v. United States, 37 Fed.Cl. 727 (1997); Cahoon v. United States, No. 95-97T (Fed. Cl. Jan. 20, 1998); Gaus v. United States, No. 95-296T (Fed.Cl. Jan. 20, 1998); Lutter v. United States, No. 95-269T (Fed.Cl. Jan. 20, 1998). The taxpayers in all four suits sought refunds of taxes, interest, and penalties...
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