OPINION OF THE COURT
SLOVITER, Circuit Judge.
I.
At issue in this case is the interpretation of a Closing Agreement between the Internal Revenue Service ("IRS") and appellant Bethlehem Steel Corporation ("Bethlehem" or "taxpayer") that preceded the payout by the IRS to Bethlehem of a refund of an anticipated overpayment of taxes, subject to later audit. Resolution of the issue depends on whether an anti-retroactivity clause in the agreement prevents...
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