This makes three wins in a row for the government on this issue concerning the scope of 28 U.S.C. sec. 1346(a)(1). The government argues that district court jurisdiction for standalone suits for overpayment interest falls under sec. 1346(a)(2), with a $10,000 limitation, instead of 1346(a)(1), which has no such limit. Accordingly, large claims must be brought in the Court of Federal Claims. Some taxpayers argue for jurisdiction under sec. 1346(a)(1), so that their suits can be brought in district court. Taxpayers had a long winning streak on this issue until recently. The Second Circuit's decision in Pfizer held for the government, creating a circuit split. Another district court soon followed the Second Circuit's lead. Now the Southern District of Florida, in the Paresky case, has done the same. There will be several opportunities soon to join battle again.