Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 3

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               Because the new statutory language [in section 6621] was               
               enacted as part of the statute that gave effect to the                 
               agreements reached at the Uruguay Round of Multilateral                
               Trade Negotiations conducted under the auspices of the                 
               General Agreement on Tariffs and Trade (“GATT”), the lower             
               corporate overpayment interest rate of 0.5 percent set forth           
               in the 1994 amendment is referred to as the “GATT rate.”               
               The higher interest rate on corporate overpayments that                
               applied to all corporate overpayments prior to the 1994 Act            
               and [that applies to corporate overpayments of $10,000 and             
               less] is referred to as the “regular rate.” * * *                      

          We use the same nomenclature herein.                                        
               Due to the 1.5-percent differential under section 6621(a)(1)           
          between the regular rate and the GATT rate, if the higher regular           
          overpayment interest rate applies to petitioners’ December 31,              
          1994, overpayment interest balance, there will accrue, after                
          December 31, 1994, additional interest in favor of petitioners of           
          approximately $450 million.                                                 

               The parties have stipulated the facts relevant to the                  
          instant motions.                                                            
               Petitioners’ corporate Federal income tax returns for 1979             
          through 1985 were timely filed with respondent.  On each of those           
          tax returns as filed, petitioners reported tax overpayments in              
          excess of $10,000 and claimed refunds or credit transfers of the            
          tax overpayments, which respondent allowed and credited in favor            
          of petitioners.                                                             

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