United States Court of Federal Claims March 2, 2012, No. 08-832T (Erlich v. United States)

MEMORANDUM OPINION AND ORDER

WOLSKI, Judge.

The motions before the Court concern whether the plaintiffs, married United States citizens who jointly file their tax returns, are allowed foreign tax credits under 26 U.S.C. § 901(b)(1) for certain taxes paid to France during tax years 2004 through 2006. Both sides have moved for partial summary judgment.