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IHNEN v. U.S.

No. 00-3799.

272 F.3d 577 (2001)

James IHNEN; Lisa Ihnen, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: November 27, 2001.

Attorney(s) appearing for the Case

Douglas E. Hoffman, Sioux Falls, SD, argued, for appellant.

Laurie A. Snyder, Department of Justice, Washington, DC, argued, for appellee.

Before BYE, BRIGHT, and RICHARD S. ARNOLD, Circuit Judges.

BRIGHT, Circuit Judge.

In August 1995, appellants James and Lisa Ihnen reached an informal agreement with the Internal Revenue Service (IRS), resolving their federal income tax liabilities for the years 1986 to 1991. In September 1998, the Ihnens filed administrative refund claims for the taxes, penalties, and interest assessed under the agreement, alleging that the IRS had erroneously determined their tax liabilities for 1986-91. The Ihnens filed these claims more...

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