- 10 - respectively. Each section has a distinct role in an integrated scheme for overpayment interest. Petitioner would read the sections in isolation to separate the overpayment from the accrued interest. This reading would have section 6621 accomplish more than simply set the interest rate. We do not interpret the change to section 6621 to bifurcate the interest rate for compounding from the overpayment interest rate. Further, the legislative history of the change and the description of the effective date in section 713(b) of the Uruguay Round Agreements Act do not support petitioner’s interpretation. Both the legislative history accompanying the 1994 amendment and the effective date language discuss a change in the rate of interest without distinguishing between the rate paid on an overpayment and the rate compounded.3 The legislative history does not state that the rate was meant to be bifurcated between interest on the overpayment itself and interest on accrued interest. We find that the importance of such a distinction leads to the conclusion that the omission was intentional. This conclusion is supported by Exxon Mobil Corp. v. Commissioner, 126 T.C. __ (2006) (slip op. at 12), filed today, finding that a “bifurcation in the interest to be paid on 3See S. Rept. 103-412, at 11 (1994) (“The outlay reductions in Title VII derive from * * * reducing the interest rate * * * with respect to large corporate tax overpayments.” (Emphasis added.)). The language in the effective date was discussed previously.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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