Rhi Holdings, Inc. v. United States
Court of Appeals for the Federal Circuit
1Opinion of the Court
GAJARSA, Circuit Judge.
In this appeal from the decision in RHI Holdings, Inc. v. United States, 37 Fed. Cl. 703 (1997), No. 95-CV-827, RHI Holdings, Inc. (RHI) appeals the determination of the Court of Federal Claims that RHI was not entitled to a refund of the “hot interest” RHI had paid under 26 U.S.C. § 6621(c) (1994). We find that the trial court should not have reached the merits of this controversy without first considering whether or not it had jurisdiction over RHI’s claim. Jurisdiction does not exist in the Court of Federal Claims over the claim because it is barred by the applicable…
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