Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 14

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          refer to interest imposed by this section on such tax”), while no           
          similar provision covers overpayment interest.                              
               Under section 6511(a) a 3-year limitation period applies to            
          a refund of an “overpayment of any tax,” while a refund of                  
          overpayment interest is governed by the general 6-year period of            
          limitation applicable to claims against the Government.  28                 
          U.S.C. secs. 2401, 2501.  Gen. Instrument Corp. v. United States,           
          33 Fed. Cl. 4, 6 (1995).                                                    
               Under section 6402(a) an overpayment “including any interest           
          allowed thereon” may be credited against a taxpayer’s other tax             
          liabilities.  Prior to 1954, however, the predecessor to section            
          6402(a) referred only to “overpayment”, and it was understood               
          that the statutory language did not allow the crediting of                  
          overpayment interest.  See S. Rept. 1622, 83d Cong., 2d Sess.               
          5230 (1954) (“This section * * * changes existing law so as to              
          permit expressly the crediting of interest on an overpayment                
          against any outstanding liability for any tax.”).                           
               Prior to 1997, under section 6512(b)(1) this Court’s                   
          jurisdiction with respect to an “overpayment” was held not to               
          include overpayment interest.  Harrison v. Commissioner, T.C.               
          Memo. 1994-614.  In 1997, section 7481(c) was amended to permit             
          us to exercise jurisdiction over some overpayment interest.                 
               In Rev. Proc. 87-43, 1987-2 C.B. 590, respondent took the              
          position that section 6601(c) (which at that time suspended the             

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