(Bloomberg) Ford Motor Co. lost another bid to recoup $445 million in interest on overpayment of income taxes, with an appeals court in Cincinnati, Ohio, blaming inconsistent tax agency rules for its denial.

Ford sued the U.S. in 2008 claiming it was shortchanged on interest accrued on cash-bond deposits it made to the Internal Revenue Service to cover possible underpayments that occurred between 1983 and 1994.

Taxpayers get interest on money paid to the government before a final decision is made on whether taxes are actually owed, according to the appeals court. Ford deposited cash bonds as security, rather than advance payments, and wasn’t eligible for the interest as a result, the panel said.

“No matter how we decide this case, taxpayers will have reason to complain about inconsistencies in the IRS’s practices,” the appeals panel said. “There is nothing we can do to rectify the IRS’s inconsistent treatment of cash-bond deposits.”

The Cincinnati-based appeals court was ordered by the Supreme Court to review the case after initially having denied Ford’s appeal in 2012.

“We are disappointed in the result and are considering our options for next steps,” said Whitney Eichinger, a spokeswoman for Ford.

Ford had argued that interest should have accrued retroactively once it changed the designation of the payments from cash-bond deposits to advance payments toward any additional taxes it might owe. The IRS countered that the starting date should be when Ford told the agency to treat the money as advance payments.

The U.S. offered to compensate Ford for the time-value of the payments on the condition the company submit to the IRS’s refund procedures. Ford declined, the appeals court said.

The case is Ford Motor Co. v U.S., 10-1934, U.S. Court of Appeals for the Sixth Circuit (Cincinnati).

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