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The Tide Keeps Going Out, Carrying Overpayment Interest Suits Away From District Courts
Procedurally Taxing blog (2020)
  • Robert D. Probasco, Texas A&M University School of Law
Abstract
Recent opinions continue to move away from a 2005 decision by the Sixth Circuit (Scripps) that ruled taxpayers could pursue stand-alone suits for overpayment interest in excess of $10,000 in district court rather than the Court of Federal Claims. In addition to the Second Circuit's decision in Pfizer, the Federal Circuit has now come to the same conclusion in Bank of America.
Keywords
  • tax,
  • overpayment interest,
  • jurisdiction,
  • district court,
  • Court of Federal Claims,
  • Scripps,
  • Pfizer,
  • Bank of America
Disciplines
Publication Date
July 6, 2020
Citation Information
Robert D. Probasco. "The Tide Keeps Going Out, Carrying Overpayment Interest Suits Away From District Courts" Procedurally Taxing blog (2020)
Available at: http://works.bepress.com/robert-probasco/103/