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scheme is not easy to unravel, the most straightforward
interpretation of the statutory language leads us to reject
[the taxpayer’s] submission.
In Gen. Elec. Co. v. United States, 56 Fed. Cl. at 496, the
Court of Federal Claims explained its holding, in part, as
follows:
The GATT rate merely attaches prospective impact to the
meeting of a condition as of the effective date of the
statute, to wit, the existence of an overpayment for the
relevant taxable year that exceeds $10,000. * * *
Petitioners read the language of section 6621(a)(1) (“to the
extent that an overpayment of tax * * * exceeds $10,000") as
providing more than the trigger for application of the GATT rate.
Petitioners read that language as limiting application of the
GATT rate to just the “overpaid taxes” and interest accruing on
the overpaid taxes after December 31, 1994, and petitioners
describe the December 31, 1994, accrued overpayment interest
balance as neither “‘tax’ nor something that was ever ‘overpaid’”
by petitioners.
Petitioners refer us to Code sections and to various
situations in which overpayment interest is or has been treated
differently from overpayments of tax and from underpayment
interest. For example, section 6601(e)(1) specifically provides
that any reference to “tax” shall also refer to underpayment
interest (“any tax imposed by this title shall be deemed also to
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