The U.S. Court of Appeals for the Second Circuit and the U.S. District Court for the Southern District of New York. Photo: Ken Lund
The U.S. Court of Appeals for the Second Circuit ruled Monday that a lower court lacked jurisdiction over Pfizer Inc.’s challenge to more than $8 million in interest it was denied for overpaying the Internal Revenue Service on its 2008 tax returns, saying the lawsuit could only be brought in U.S. Federal Claims Court.
The decision from a three-judge panel of the appeals court exposed a circuit split on whether a dispute for “overpayment interest” qualifies as the type of action that gives federal district courts concurrent jurisdiction over such suits involving the IRS.
