OPINION MILLER, Judge. This tax ease is before the court on defendant’s motion to dismiss for lack of jurisdiction under RCFC 12(b)(1) or for failure to state a claim under RCFC 12(b)(4). Defendant’s motion raises as its principal issue whether plaintiffs’ claim for a refund is barred by the statute of limitations because the carryback for losses that plaintiffs claim is predicated on a persona…
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