POSNER, Chief Judge.
The United States sued National Steel Corporation seeking the return of so much of an income-tax refund as the United States believed exceeded National Steel's actual entitlement. The district court granted summary judgment for the United States and ordered National Steel to pay back the excess portion of the refund, some $2.5 million, plus interest, precipitating this appeal.
Section 212(a) of the Tax Reform Act of 1986, 100 Stat. 2170...
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