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BROWN v. UNITED STATES

2021-1721.

22 F.4th 1008 (2022)

George P. BROWN, Ruth Hunt-Brown, Plaintiffs-Appellants, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Decided: January 5, 2022.

Attorney(s) appearing for the Case

Tiffany Michelle Hunt , Barnes & Hunt, PLLC, Dallas, TX, argued for plaintiffs-appellants.

Isaac B. Rosenberg , Appellate Section, Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellee. Also represented by Bruce R. Ellisen , David A. Hubbert .

Keith Fogg , Tax Clinic of the Legal Services Center of Harvard Law School, Jamaica Plain, MA, for amicus curiae The Center for Taxpayer Rights. Also represented by Carlton M. Smith , New York, NY.

Before Lourie, Dyk, and Stoll, Circuit Judges.

George P. Brown and Ruth Hunt-Brown appeal from the decision of the United States Court of Federal Claims (the "Claims Court") dismissing their tax refund suit for lack of subject matter jurisdiction. See Brown v. U.S., 151 Fed. Cl. 530 (2020) ("Decision"). While we disagree that the court lacked jurisdiction...

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