curiam); see also Singleton v. United States, 128 F.3d 833, 838-39 (4th Cir.1997); Brookhurst, Inc. v. United rebate refunds as tax amounts that increase a taxpayer’s assessable deficiency). But see Bilzerian, 86 F.3d at 1069 (stating, in dicta, that “once a tax liability is paid, no erroneous refund— whether rebate or non-rebate — can revive it”). This principle has already been applied in this case. The Greers originally paid their 1979-1981 tax liabilities in full; their underpayment for those years was the result of rebate refunds made after they submitted amended returns in 1982 claiming carryback tax benefits from their Madison investment. Those rebate refunds were erroneous because the IRS later disallowed the tax benefits on which they were premised. Cf. Beer, 733 F.2d at 436 (<HOLDING>). By assessing the amount of the 1982 rebate
holding that refunds issued based on a claimed exemption that was later disallowed are erroneous holding that injunction was not properly issued based on threats to make the petitioners life miserable holding that summons issued nearly seven months after the show cause order was entered was not issued immediately as required by statute holding that courts of appeals should review the facts necessary to determine whether an exemption to the flsa applies in a particular under the clearly erroneous standard recognizing that appellate court may reverse trial courts judgment when it is based on an erroneous conclusion of law