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STATE OF MICH. v. U.S.

No. 97-1185.

141 F.3d 662 (1998)

STATE OF MICHIGAN and its Michigan Education Trust, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided April 15, 1998.

Attorney(s) appearing for the Case

Michael W. Hartmann (argued and briefed), Karl N. Gellert (briefed), Miller, Canfield, Paddock & Stone, Detroit, MI, for Plaintiffs-Appellants.

Richard Farber (argued and briefed), Steven W. Parks (briefed), U.S. Department of Justice, Appellate Section Tax Division, Washington, DC, for Defendant-Appellee.

Before: RYAN, COLE, and GILMAN, Circuit Judges.

GILMAN, Circuit Judge.

The state of Michigan and its Michigan Education Trust (collectively "MET") appeal from a judgment entered in favor of the Internal Revenue Service (the "IRS") regarding when interest should accrue on estimated tax payments made under protest by MET and subsequently refunded by the IRS. The IRS, which concedes MET's entitlement to interest on the amounts refunded, determined that such interest should...

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