Exxon Mobil Corporation and Affilliated Companies, f.k.a. Exxon Corporation and Affiliated Companies - Page 17

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               Petitioners suggest that their calculations are supported by           
          the manner by which interest calculations routinely are adjusted            
          in commercial debtor-creditor relationships for changes either in           
          the principal amount outstanding or in the interest rate.  We               
          disagree.  The “wrinkle” petitioners acknowledge herein that is             
          not typical in the routine debtor-creditor relationship is that             
          petitioners seek to apply the reduced interest rate not to the              
          full outstanding balance of the overpayment interest on the                 
          effective date of the rate reduction but only to a portion                  
          thereof.  It is that wrinkle that is in issue, and we find no               
          support in petitioners’ examples for the proposition petitioners            
          seem to put forth that under commercial debtor-creditor loan                
          agreements a prospective reduction in the applicable interest               
          rate similar to that reflected in the GATT amendment necessarily            
          would not apply to overpayment interest balance on the effective            
          date of the rate reduction.                                                 
               We conclude that petitioners’ December 31, 1994,                       
          $1.6 billion overpayment interest balance accrues interest after            
          December 31, 1994, at the reduced GATT rate.                                
               As a related issue, petitioners contend that under section             
          6621(a)(1) the $10,000 exemption from the reduced GATT rate                 
          should apply to the last $10,000 of their tax overpayment for               
          each year.                                                                  

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