Ford Motor Company v. United States

PETITIONER: Ford Motor Company
RESPONDENT: United States
LOCATION: Ford Motor Company Headquarters

DOCKET NO.: 13-113
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT:

CITATION: 571 US (2013)
GRANTED: Dec 02, 2013
DECIDED: Dec 02, 2013

Facts of the case

When a taxpayer overpays his taxes, he is entitled to interest from the government for the period between the date of overpayment and the ultimate refund, but the "date of overpayment" is not specifically defined.

The Internal Revenue Service (IRS) informed the Ford Motor Company (Ford) that it had underpaid on its taxes between 1983 and 1989. Ford subsequently submitted deposits to the IRS that covered the underpayment. Ford later requested that the deposits be considered to cover additional taxes that Ford owed. The parties eventually determined that Ford had overpaid its taxes and was owed a refund. Ford argued that the date of overpayment was the date that it first submitted the deposits to the IRS for the underpayment of taxes, and the Government argued that the date of overpayment was the date when Ford requested that the payment cover additional taxes. Ford sued the Government in federal district court, and the court found in favor of the Government. The U.S. Court of Appeals for the Sixth Circuit affirmed.

Question

Did the U.S. Court of Appeals for the Sixth Circuit properly hear and decide the case?