PHILADELPHIA ENERGY SOLUTIONS REFINING v. US , No. 22-1834 (Fed. Cir. 2024)
Annotate this CaseIn this case, the United States Court of Appeals for the Federal Circuit ruled against Philadelphia Energy Solutions Refining and Marketing, LLC ("Philadelphia Energy"). Philadelphia Energy, a fuel producer, had appealed a decision by the United States Court of Federal Claims denying their claim for tax refunds for excise taxes they had paid on fuel mixtures of butane and gasoline. Philadelphia Energy argued that these fuel mixtures should be considered "alternative fuel mixtures" under 26 U.S.C. § 6426(e), making them eligible for a tax credit. However, the Court of Appeals upheld the lower court's decision, finding that butane, despite being considered a liquefied petroleum gas, is not considered an "alternative fuel" under this statute. This is because butane is also a "taxable fuel," and the statutory language creates a dichotomy between "taxable fuels" and "special motor fuels", with the two being mutually exclusive. Consequently, Philadelphia Energy's mixture of butane and gasoline does not qualify for the alternative fuel mixture credit, and they are not entitled to the claimed tax refunds.
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