ERLICH v. U.S.

No. 08-832T.

ANDRE B. ERLICH and TERESA I. POZNANSKI-ERLICH, Plaintiffs, v. THE UNITED STATES, Defendant.

United States Court of Federal Claims.

March 2, 2012.


Attorney(s) appearing for the Case

Stuart E. Horwich, Washington, D.C., for Plaintiff.

Michael J. Ronickher, Court of Federal Claims Section, Tax Division, Department of Justice, with whom were John A. DiCicco, Acting Assistant Attorney General, Steven I. Frahm, Chief, Court of Federal Claims Section, all of Washington, D.C., for Defendant. Mary M. Abate, Washington, D.C., of counsel.


Partial summary judgment; foreign tax credit, 26 U.S.C. § 901(b)(1); Section 317(b)(4) of the Social Security Amendments of 1977; Totalization Agreement, 42 U.S.C. § 433; plain meaning of "in accordance with the terms"; loss of tax credit for French social security payments by U.S. citizen employed by non-American corporation in France.

VICTOR J. WOLSKI, Judge.

MEMORANDUM OPINION AND ORDER

The motions before the...

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