- 17 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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