884 F.3d 1151 (2018)

Wilton R. STEPHENS, Jr., Carol M. Stephens, Plaintiffs-Appellants v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Decided: March 9, 2018.

Attorney(s) appearing for the Case

CRAIG S. LAIR , Rose Law Firm, Little Rock, AR, argued for plaintiffs-appellants. Also represented by BYRON JANSEN WALKER.

ANTHONY T. SHEEHAN , Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellee. Also represented by DAVID A. HUBBERT , JONATHAN S. COHEN.

Before Newman, Wallach, and Chen, Circuit Judges.

Appellants Wilton R. Stephens, Jr., and Carol M. Stephens (collectively, the "Stephenses") sued the United States (Government) in the U.S. Court of Federal Claims ("Claims Court"), seeking a refund of federal income taxes and interest. The Government filed a motion to dismiss for lack of subject matter jurisdiction pursuant...

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