Maimonides Medical Center v. United States, No. 14-4279 (2d Cir. 2015)Annotate this Case
MMC and the government agreed that MMC is entitled to an overpayment refund and further agree on the amount of that overpayment, but disagree on the interest rate to be applied. MMC argues that, despite being organized as a corporation under New York law, it should receive the benefit of the higher interest rate applicable to non‐corporations, because it is a nonprofit corporation and the word “corporation” in I.R.C. 6621(a)(1) should be construed to refer only to for‐profit corporations. The court held that I.R.C. 6621(a)(1)'s lower interest rate applies equally to for-profit corporations and nonprofit corporations such as MMC. Accordingly, the court affirmed the judgment of the district court.