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JEWELL v. U.S.

No. 08-1175.

548 F.3d 1168 (2008)

Barry J. JEWELL, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Eighth Circuit.

Filed: December 10, 2008.

Attorney(s) appearing for the Case

Carol Barthel, DOJ, argued, Kenneth Greene, on the brief, Washington, DC, for appellant.

Before RILEY, BRIGHT, and MELLOY, Circuit Judges.

BRIGHT, Circuit Judge.

This appeal stems from a civil action brought by appellee Barry J. Jewell against appellant the United States ("the IRS") seeking a refund of his pro rata share of a tax sanction paid in conjunction with a closing agreement between his former law firm and the IRS. On appeal, the IRS challenges the decisions of the district court (1) denying the IRS's motion to dismiss the complaint for lack of standing...

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