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BANK OF AMERICA CORP. v. U.S.

2019-2357.

964 F.3d 1099 (2020)

BANK OF AMERICA CORPORATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Federal Circuit.

Decided: July 2, 2020.

Attorney(s) appearing for the Case

Timothy S. Bishop , Mayer Brown, LLP, Chicago, IL, argued for plaintiff-appellee. Also represented by Marjorie Margolies ; Geoffrey M. Collins , Croton-on-Hudson, NY; Brian Wright Kittle , New York, NY.

Norah Bringer , Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellant. Also represented by Ellen Page DelSole , Richard E. Zuckerman .

Before Lourie, Linn, and Wallach, Circuit Judges.

Appellee Bank of America Corporation ("Bank of America") filed a complaint against Appellant the United States ("Government") in the U.S. District Court for the Western District of North Carolina ("District Court"), seeking, inter alia, interest on Federal tax overpayments arising under 26 U.S.C. § 6611. The Government...

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