United States Court of Federal Claims February 21, 2007, No. 06-115C (Simons v. United States)

*507MEMORANDUM OPINION AND FINAL JUDGMENT

BRADEN, Judge.

I. RELEVANT FACTS AND PROCEDURAL HISTORY.1

This ease arises from a long-standing dispute between Plaintiffs and the Internal Revenue Service (“IRS”) regarding two settlement agreements that were intended to resolve all litigation concerning disputed tax payments made in the 1970s and 1980s.