Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 2

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               Robert L. Moore II, Thomas D. Johnston, and Kevin Kenworthy,           
          for petitioners.                                                            

               Robert M. Morrison, for respondent.                                    

               SWIFT, Judge:  This matter is before us on petitioners’                
          motions under section 7481(c) and Rule 261 for the Court to                 
          determine the correct amount of overpayment interest due                    
               The primary issue presented is whether petitioners’                    
          cumulative accrued overpayment interest balance outstanding on              
          December 31, 1994, of approximately $1.6 billion (relating to               
          petitioners’ consolidated Federal income taxes for 1979 through             
          1985) accrues compound interest thereafter until paid to                    
          petitioners at the regular corporate overpayment interest rate,             
          as petitioners contend, or at the reduced overpayment interest              
          rate applicable to large corporate overpayments, as respondent              
               In its discussion of essentially the same question of                  
          statutory interpretation presented herein, the Court of Appeals             
          for the Federal Circuit in Gen. Elec. Co. v. United States, 384             
          F.3d 1307, 1309 (Fed. Cir. 2004), explained:                                

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           

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