State Farm Mutual Automobile Insurance Company and Subsidiaries - Page 5

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          the overpayment of tax previously determined by this Court with             
          respect to its taxable year 1987, and the parties have filed                
          memoranda on the issue raised.                                              
               Petitioner also disputes that $10,000 of the overpayment due           
          on the effective date should receive the regular rate of interest           
          rather than the GATT rate.  Respondent counters that the                    
          refunding of more than $10,000 of the original overpayment on the           
          due date of petitioner’s return relieves the need for any further           
          application of the $10,000 threshold in section 6621(a)(1).                 
                                     Discussion                                       
               Interest on overpayments is authorized by section 6611(a) at           
          the rate established in section 6621.  Section 6622(a) requires             
          that the overpayment interest be compounded daily.  The issue               
          before us concerns whether the GATT rate change in corporate                
          overpayment interest applies in computing interest on the                   
          interest accrued before the effective date.  This change results            
          in 1.5 percent less interest after December 31, 1994.  The                  
          following sentence was added to section 6621(a)(1) by the Uruguay           
          Round Agreements Act, Pub. L. 103-465, sec. 713(a), 108 Stat.               
          5001 (1994):                                                                
               To the extent that an overpayment of tax by a                          
               corporation for any taxable period (as defined in                      
               subsection (c)(3)) exceeds $10,000, subparagraph (B)                   
               shall be applied by substituting “0.5 percentage point”                
               for “2 percentage points.”                                             







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