Roberta BORENSTEIN, Petitioner-Appellant,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued: November 13, 2018.
Decided: April 2, 2019.
Attorney(s) appearing for the Case
KENDALL C. JONES , Eversheds Sutherland (US) LLP, Washington, D.C., for Petitioner-Appellant.
IVAN C. DALE , Tax Division ( Richard E. Zuckerman , Principal Deputy Assistant Attorney General; Joan I. Oppenheimer , Tax Division, on the brief), United States Department of Justice, Washington, D.C., for Respondent-Appellee.
T. KEITH FOGG ( Simona Altshuler , on the brief), Federal Tax Clinic at the Legal Services Center of Harvard Law School, Jamaica Plain, MA; W. EDWARD AFIELD , Philip C. Cook Low-Income Taxpayer Clinic, Atlanta, GA; for Amici Curiae Federal Tax Clinic at the Legal Services Center of Harvard Law School, Philip C. Cook Low-Income Taxpayer Clinic, in support of Petitioner-Appellant.
Before: JACOBS, POOLER, WESLEY, Circuit Judges.
Dennis Jacobs, Circuit Judge:
Roberta Borenstein appeals from a judgment of the United States Tax Court (Lauber, J.) denying her petition seeking refund of her overpayment of 2012 income tax. The Commissioner of Internal Revenue ("the Commissioner") and Borenstein do not dispute that she overpaid, or the amount of her overpayment...
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