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CHARLESTON AREA MEDICAL CENTER, INC. v. U.S.

2018-2226.

940 F.3d 1362 (2019)

CHARLESTON AREA MEDICAL CENTER, INC., CAMC Health Education and Research Institute, Inc., on behalf of Themselves and All Other Taxpayers Similarly Situated, Plaintiffs-Appellants v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Decided: October 17, 2019.

Attorney(s) appearing for the Case

Thomas D. Sykes , Law Offices of Thomas D. Sykes, LLC, Lake Forest, IL, argued for plaintiffs-appellants.

Jennifer Marie Rubin , Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellee. Also represented by Deborah K. Snyder , Richard E. Zuckerman .

Before Lourie, O'Malley, and Chen, Circuit Judges.

This case is about the interpretation of 26 U.S.C. § 6621(a)(1), which provides the interest rate that the Internal Revenue Service ("IRS") must use in calculating the amount of interest owed on a tax refund. Section 6621(a)(1) requires the IRS to apply a lower interest rate for refunds owed to "corporations" than for...

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