(Bloomberg) — The Obama administration asked the full U.S. Court of Appeals in Washington to reconsider a three-judge panel ruling that customers on the federal marketplace authorized by the health-care overhaul are ineligible for subsidies to buy insurance.

"The text, structure, and purpose" of the overhaul "make clear that tax credits are available to consumers 'regardless of whether the exchange on which they purchased their health insurance coverage is a creature of the state or the federal bureaucracy,'" government lawyers wrote in a request for re-hearing filed today.

The request is the first step in efforts to undo a 2-1 ruling on July 22 striking down an Internal Revenue Service rule providing the subsidies for needy customers on the insurance exchange run by the federal government.