United States Supreme Court

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Ford Motor Co. v. US, 13-113

In a suit to recover interest from the government on plaintiff's tax overpayment for the period between the payment and the ultimate refund, the Sixth Circuit's judgment that 26 U.S.C. section 6611(a) should be strictly construed in favor of the government, and the date of overpayment was the date that plaintiff requested that the IRS treat the remittances as payments of tax, is vacated and remanded, where: 1) the government now argues that the only basis for jurisdiction, and the only general waiver of sovereign immunity that encompasses plaintiff's claim, is the Tucker Act, 28 U.S.C. section 1491(a); and 2) the Sixth Circuit should have the first opportunity to consider the government's new contention with respect to jurisdiction in this case.

Appellate Information

  • Decided 12/02/2013
  • Published 12/02/2013

Judges

  • PER CURIAM

Court

  • United States Supreme Court

Counsel