SAN FRANCISCO (AP) A federal appeals court has ruled against late Oakland Raiders owner Al Davis and his wife, Carol, in a fight with the IRS over about $2.5 million in tax assessments.

The court ruled Monday that the assessments for 1990, 1992 and 1995 were valid, though the IRS breached a contract with Al Davis. The decision by the 9th U.S. Circuit Court of Appeals reversed a lower court ruling.

The contract at issue entitled Davis and other Raiders partners to review the tax bills before they were assessed. The IRS failed to honor that part of the contract, prompting Davis to sue for a refund.

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Al Davis died in 2011, and his son, Mark, now owns the Raiders. A call to an attorney for Carol Davis was not immediately returned.