Taxpayers who pay more tax than is due have the right to sue
for a refund after exhausting their administrative remedies, and they may file
suit either in a district court or in the Court of Federal Claims, as the
courts have concurrent jurisdiction. 28 U.S.C. § 1346(a)(1).

In addition to recovering the excess tax, taxpayers are
entitled to overpayment interest. I.R.C. § 6611(a). Normally, the tax and the
interest travel together, but in some cases, the taxpayer receives her refund
but a dispute about the correct amount of overpayment interest arises. For
large taxpayers, the interest on an overpayment can be quite significant.… Read More