Strategic Housing Finance Corp. v. United States

GAJARSA, Circuit Judge.

The issue before this court is whether a bond issuer must first seek an administrative refund for an arbitrage rebate from the Internal Revenue Service (“IRS”) before filing a suit for a refund in the U.S. Court of Federal Claims (“CFC”). Strategic Housing Finance Corp. of Travis County, Texas (“Strategic Housing”), appeals from the CFC’s order dismissing Strategic Housing’s suit against the United States to recover its arbitrage rebate. In its complaint before the CFC, Strategic Housing alleged, among other things, that the United States required it to remit the…