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Maine Medical Center v. United States

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Before Lynch, Chief Judge, Souter, Associate Justice, *fn1 and Stahl, Circuit Judge.

Maine Medical Center’s (MMC) tax refund suit stalled when the district court found that jurisdictional discovery was not warranted and that without such discovery, MMC could not meet its burden of demonstrating jurisdiction. MMC appealed the district court’s judgment for the government, arguing that it had offered sufficient evidence to merit jurisdictional discovery. Ultimately, MMC did not make an adequate threshold showing that its refund claim was timely filed, and thus the district court ruled that it did not have jurisdiction to hear the case. After careful review, we affirm.

I. Facts & Background

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