81 F.4th 1378 (2023)

GSS HOLDINGS (LIBERTY) INC., Plaintiff-Appellant, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Decided: September 21, 2023.

Attorney(s) appearing for the Case

Andrew John Pincus , Mayer Brown LLP, Washington, DC, argued for plaintiff-appellant. Also represented by Samantha Bear , Timothy S. Bishop , Chicago, IL; Geoffrey M. Collins , Brian Wright Kittle , New York, NY.

Sherra Tinyi Wong , Tax Division, Appellate Section, United States Department of Justice, Washington, DC, argued for defendant-appellee. Also represented by Jacob Earl Christensen , David A. Hubbert .

Dissenting opinion filed by Circuit Judge Newman.

GSS Holdings (Liberty) Inc. ("GSS") appeals from a decision of the United States Court of Federal Claims ("Claims Court") granting summary judgment in favor of the government and denying summary judgment in favor of GSS with respect to GSS's 2011 deduction claim for a federal tax refund or credit for the tax year ending...

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