United States Court of Federal Claims November 30, 2006, No. 06-115C (Simons v. United States)

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United States · · · 30-11-2006

MEMORANDUM OPINION AND ORDER

BRADEN, Judge.

I. RELEVANT FACTS1

This case involves a long-term dispute between Plaintiffs and the Internal Revenue *711Service (“IRS” or “Government”) arising from two settlement agreements concerning tax returns filed by Plaintiffs in the 1970s and 1980s.

A. First Settlement Agreement.

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