Wichita Ctr. for Graduate Med. Educ., Inc. v. United States

TYMKOVICH, Chief Judge.

Wichita Center of Graduate Medical Education is a federally qualified charitable organization incorporated under the laws of Kansas. In 2010, the Internal Revenue Service issued a refund to the Center on overpaid taxes along with incorrectly calculated interest on the refund. The IRS then sought repayment of part of the interest. Under the Internal Revenue Code, corporate taxpayers receive a lower refund interest rate than other taxpayers such as individuals or partnerships. 26 U.S.C. § 6621 (a)(1). The Center claims it is not a corporation for purposes of this section…