Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 11

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          with respect to that corporation (and with respect to all                   
          overpayment interest accrual except that relating to the                    
          corporation’s tax overpayment up to $10,000), section 6621(a)(1)            
          effectively provides only one interest rate –- the reduced GATT             
               In the above situation, in effect (for everything other than           
          interest relating to a corporation’s tax overpayment up to                  
          $10,000) the regular interest rate, for practical purposes, is              
          eliminated from the statutory language of section 6221, and there           
          remains in section 6621(a)(1) only one interest rate –– the GATT            
          rate -- that applies to all further interest accrual relating to            
          corporate overpayments of tax and to accrual of compound interest           
               Section 6621(a)(1) does not refer to overpayment “rates”.              
          Once the GATT trigger occurs, then any and all further interest             
          after December 31, 1994, relating to or associated with that                
          excess corporate overpayment, is to accrue only at the reduced              
          GATT rate.                                                                  
               Our interpretation of the statutory language is supported by           
          the holding of this Court in State Farm Mut. Auto. Ins. Co. v.              
          Commissioner, 126 T.C.     (2006), filed today, and also by the             
          recent holdings of the Court of Appeals for the Federal Circuit             
          and the U.S. Court of Federal Claims in Gen. Elec. Co. v. United            

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