the United States for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected.” Essentially, the State seeks a tax refund. The federal government argues that the contributions imposed under the Transitional Reinsurance Program do not constitute an “internal-revenue tax,” and- thus, do not fall under the jurisdictional grant from 28 U.S.C. § 1346(a)(1). The federal government cites a recent case from the Tenth Circuit, where that court held that a “coal reclamation fee” assessed by the Department of the Interior did not constitute an “internal-revenue tax” within the meaning of § 1346(a)(1); thus depriving the district court of subject-matter jurisdiction. Wyodak Res. Dev. Corp. v. United States, 637 F.3d 1127, 1129 (10th Cir.2011) (<HOLDING>). The Sixth Circuit, however, takes a “broader
holding that plaintiffs claim properly belonged only in the court of federal claims under 28 usc  1491 holding that the plain language of 42 usc  4654c precludes the court from including in its award to the plaintiffs any reimbursement for expenses incurred by the plaintiffs before they decided to file suit in the court of claims under 28 usc  1491 holding that the court of federal claims had pendant jurisdiction over a state law contract claim that was part of the same case as a claim over which the court of federal claims had jurisdiction pursuant to 28 usc  1498b holding that  ijinguistic consistency  required that the same arising under test be applied to the jurisdictional statute for patent claims 28 usc  1338a as is used for the general federal jurisdiction statute 28 usc  1331 holding that under the fsia personal jurisdiction   depends upon the district court finding subject matter jurisdiction under 28 usc  1330a and proper service under 28 usc  1608