126 T.C. No. 2 UNITED STATES TAX COURT STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1859-01. Filed January 17, 2006. P filed a Motion Pursuant to Rule 261 to Redetermine Interest on Overpayment. The issue raised in P’s motion is whether accrued interest on P’s overpayment as of Dec. 31, 1994, is subject to the regular rate of interest or the lower rate of interest provided by sec. 6621(a)(1), I.R.C., beginning on Jan. 1, 1995 (the GATT rate). R’s position that the GATT rate applies was previously sustained by the Court of Federal Claims and the Court of Appeals for the Federal Circuit in Gen. Elec. Co. v. United States, 384 F.3d 1307 (Fed. Cir. 2004), affg. in part and remanding in part 56 Fed. Cl. 488 (2003). See also Exxon Mobil Corp. v. Commissioner, 126 T.C. (2006). The parties also dispute whether any portion of the overpayment remains subject to the $10,000 threshold as provided in sec. 6621(a)(1), I.R.C. Held: We hold that the GATT rate applies to the accrued interest owed P as of Dec. 31, 1994.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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