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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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