The E.W. Scripps Company and Subsidiaries v. United States
Court of Appeals for the Sixth Circuit
1Opinion of the Court
OPINION
MOORE, Circuit Judge.
In the underlying action, Plaintiff-Ap-pellee The E.W. Scripps Company and Subsidiaries (“Scripps”) seeks to recover interest payments from Defendant-Appellant United States of America (“the Government”) based on Scripps’s overpayment of tax. On appeal, the Government has not challenged the district court’s determination that Scripps is entitled to statutory interest because the $3.5 million Scripps tendered to the Internal Revenue Service (“IRS”) constituted a payment of tax rather than a cash bond. Instead, the Government has asserted only that the district court…
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