Manor Care, Inc. v. United States

*619 OPINION

BASKIR, Judge.

This is a tax refund ease brought under the Tucker Act, 28 U.S.C. § 1491(a)(1). Plaintiffs, Manor Care, Inc.; HCR Manor Care, Inc.; and Manor Care of America, Inc. (collectively Manor Care or plaintiffs), seek refunds measured by wages paid to approximately 3,000 new employees whom they contend are members of statutorily defined targeted groups, which entitled the employer to take certain tax credits.

Plaintiffs contend that they should have been permitted to claim the tax credits despite the fact that the employees were denied certification as belonging to those groups…