U.S. Court of Federal Claims Issues Reported Memorandum and Order Involving David and Evelyn Shnier
The U.S. Court of Federal Claims issued the following reported opinion and order (Case No. 18-1257):
(Filed: 17 November 2020)
DAVID C. SHNIER & EVELYN Z. SHNIER, Plaintiffs, v. THE UNITED STATES, Defendant
Pro Se; Tax Refund Claim; RCFC 56; Motion for Summary Judgment; 26 I.R.C. Sec. 1297; Passive Foreign Investment Company ("PFIC"); Taxpayer Bill of Rights ("TBOR"); 26 I.R.C. Sec. 7803(a)(3)
David C. Shnier and Evelyn Z. Shnier, pro se, of Baltimore, MD, for plaintiffs.
Miranda Bureau, Trial Attorney, with whom were Mary M. Abate, Assistant Chief, David I. Pincus, Chief, Court of Federal Claims Section, and Richard E. Zuckerman, Principal Deputy Assistant Attorney General, Department of Justice, all of Washingto...