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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
rate.
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
thereon.
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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