United States v. Detroit Medical Center

OPINION

SUTTON, Circuit Judge.

Detroit Medical Center is made up of a collection of not-for-profit hospitals incorporated under Michigan law. The Center overpaid its taxes, entitling it to a refund plus interest. Under the Internal Revenue Code, “corporations” receive lower interest rates on such refunds (the federal short-term interest rate plus as little as 0.5%) than other taxpayers (the federal short-term interest rate plus 3%). 26 U.S.C. § 6621(a)(1). The Center claims that, as a not-for-profit corporation, it should not be treated as a corporation and thus should be eligible for the…