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respectively. Each section has a distinct role in an integrated
scheme for overpayment interest.
Petitioner would read the sections in isolation to separate
the overpayment from the accrued interest. This reading would
have section 6621 accomplish more than simply set the interest
rate. We do not interpret the change to section 6621 to
bifurcate the interest rate for compounding from the overpayment
interest rate. Further, the legislative history of the change
and the description of the effective date in section 713(b) of
the Uruguay Round Agreements Act do not support petitioner’s
interpretation. Both the legislative history accompanying the
1994 amendment and the effective date language discuss a change
in the rate of interest without distinguishing between the rate
paid on an overpayment and the rate compounded.3 The legislative
history does not state that the rate was meant to be bifurcated
between interest on the overpayment itself and interest on
accrued interest. We find that the importance of such a
distinction leads to the conclusion that the omission was
intentional. This conclusion is supported by Exxon Mobil Corp.
v. Commissioner, 126 T.C. __ (2006) (slip op. at 12), filed
today, finding that a “bifurcation in the interest to be paid on
3See S. Rept. 103-412, at 11 (1994) (“The outlay reductions
in Title VII derive from * * * reducing the interest rate * * *
with respect to large corporate tax overpayments.” (Emphasis
added.)). The language in the effective date was discussed
previously.
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