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GENERAL MILLS, INC. v. U.S.

2019-1124.

957 F.3d 1275 (2020)

GENERAL MILLS, INC. and Subsidiaries, Plaintiff-Appellant, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Decided: April 23, 2020.

Attorney(s) appearing for the Case

Sheri Dillon , Morgan, Lewis & Bockius LLP, Washington, DC, argued for plaintiff-appellant. Also represented by Jennifer Breen , William Nelson , James Gaston Steele, III .

Julie Ciamporcero Avetta , Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellee. Also represented by Arthur Thomas Catterall , Richard E. Zuckerman .

Dissenting opinion filed by Circuit Judge Newman.

General Mills, Inc. & Subsidiaries (collectively, GMI) sued the United States seeking refunds of interest it paid on corporate income tax underpayments that the Internal Revenue Service (IRS) assessed at the enhanced rate of interest for "large corporate underpayments" (LCU) set forth in Internal Revenue Code (I.R.C.) &...

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