Can district courts hear stand-alone cases for additional interest on tax overpayments as a "tax refund suit" (no dollar limitation) rather than a "little Tucker Act claim" ($10,000 limit)? The Eleventh Circuit has now joined the Second and Federal Circuits is saying "No," rejecting a 2005 decision in the Sixth Circuit. In some instances, that may mean moving the case to another forum that might be less favorable. For these victims of Bernie Madoff, it means they no longer have judicial review on the merits of their refund claim.