NALBANDIAN, Circuit Judge. Delek, a fuel producer, contends that it overpaid its income taxes and seeks a refund. The IRS counters that what Delek really wants to do is double dip. Delek earned a tax credit by mixing renewables into its products. Since that credit applies against the fuel excise tax, Delek ended up paying less in excise taxes. But Delek insists it should be deemed to have paid the full, unreduced amount of excise tax. Why would it say that? When calculating its gross income, a producer can include its excise tax liability in its cost of goods sold. And a higher cost of goods sold means a lower gross income, which means a lower income tax liability.

To that end, Delek offers a novel theory: The credit is a “payment” that satisfies, but does not reduce, its excise tax liability. But the statute’s plain meaning says otherwise, and we AFFIRM summary judgment in the government’s favor.