Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 5

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          been resolved, and decisions have been entered in each of these             
          consolidated cases.                                                         

                                     Discussion                                       
               We start our analysis of the legal question before us with             
          the language and structure of the statute itself.  Kaiser                   
          Aluminum & Chem. Corp. v. Bonjorno, 494 U.S. 827, 835 (1990);               
          United States v. Ron Pair Enters, Inc., 489 U.S. 235, 241 (1989);           
          Anderson v. Commissioner, 123 T.C. 219, 233 (2004), affd. 137               
          Fed. Appx. 373 (1st Cir. 2005).                                             
               Section 6611 provides that taxpayers are to be allowed and             
          are to be paid interest on any overpayments in respect of any               
          internal revenue tax at the rate established under section 6621.            
               Section 6622 provides that in computing the amount of                  
          interest required to be paid under section 6611, the interest               
          will be compounded daily.                                                   
              Section 6621 provides that the rate of interest to be paid             
          by respondent to corporate taxpayers on overpayments shall be               
          the sum of the Federal short-term interest rate, as calculated              
          according to the formula set forth in section 6621(b), plus 2               
          percentage points, but plus only 0.5 percentage point where a               
          corporate overpayment for a year is in excess of $10,000.                   
               The relevant text of section 6621(a)(1) provides as follows:           

                    (1) Overpayment rate.--The overpayment rate established           
               under this section shall be the sum of --                              





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