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.
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