Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 13

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               scheme is not easy to unravel, the most straightforward                
               interpretation of the statutory language leads us to reject            
               [the taxpayer’s] submission.                                           

               In Gen. Elec. Co. v. United States, 56 Fed. Cl. at 496, the            
          Court of Federal Claims explained its holding, in part, as                  

               The GATT rate merely attaches prospective impact to the                
               meeting of a condition as of the effective date of the                 
               statute, to wit, the existence of an overpayment for the               
               relevant taxable year that exceeds $10,000. * * *                      

               Petitioners read the language of section 6621(a)(1) (“to the           
          extent that an overpayment of tax * * * exceeds $10,000") as                
          providing more than the trigger for application of the GATT rate.           
          Petitioners read that language as limiting application of the               
          GATT rate to just the “overpaid taxes” and interest accruing on             
          the overpaid taxes after December 31, 1994, and petitioners                 
          describe the December 31, 1994, accrued overpayment interest                
          balance as neither “‘tax’ nor something that was ever ‘overpaid’”           
          by petitioners.                                                             
               Petitioners refer us to Code sections and to various                   
          situations in which overpayment interest is or has been treated             
          differently from overpayments of tax and from underpayment                  
          interest.  For example, section 6601(e)(1) specifically provides            
          that any reference to “tax” shall also refer to underpayment                
          interest (“any tax imposed by this title shall be deemed also to            

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