- 2 - Held, further, the entire overpayment of tax remaining is subject to the GATT rate since an amount in excess of the $10,000 threshold was refunded to P on the due date of P’s return for the taxable year in question. Jerome B. Libin, James V. Heffernan, and Mary E. Monahan, for petitioner. Robert Morrison and Jan E. Lamartine, for respondent. OPINION GOEKE, Judge: Before us is petitioner’s motion under Rule 2611 seeking a higher rate of interest on petitioner’s overpayment. The difference between petitioner’s interest computation method and respondent’s method stems from a difference of view regarding the effect of a 1994 amendment to section 6621(a)(1), the so-called GATT amendment. That amendment reduced the rate of overpayment interest applicable to that portion of a corporate tax overpayment that exceeds $10,000 for purposes of determining interest after December 31, 1994. Because we hold that the reduced rate of interest effective after December 31, 1994, applies to interest accrued on petitioner’s overpayment as of that date, petitioner’s motion will be denied. 1Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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