Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 1

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                                   126 T.C. No. 3                                     


                               UNITED STATES TAX COURT                                


           EXXON MOBIL CORPORATION AND AFFILIATED COMPANIES, f.k.a. EXXON             
                CORPORATION AND AFFILIATED COMPANIES, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 18618-89, 18432-90       Filed January 17, 2006.           
                           23331-95.                                                  


                    Held:  Under secs. 6611, 6621(a)(1) and 6622,                     
               petitioners’ outstanding Dec. 31, 1994, cumulative                     
               accrued overpayment interest balance of $1.6 billion                   
               relating to the years involved herein accrues further                  
               compound interest after Dec. 31, 1994, at the reduced                  
               interest rate applicable to large corporate                            
               overpayments, not at the regular interest rate.  Gen.                  
               Elec. Co. v. United States, 56 Fed. Cl. 488 (2003),                    
               affd. 384 F.3d 1307 (Fed. Cir. 2004), and State Farm                   
               Mut. Auto. Ins. Co. v. Commissioner, 126 T.C.                          
               (2006), followed.  Petitioners’ claim for an additional                
               $450 million in accrued interest is denied.