Ford Motor Company v. United States

Corporate tax case; interest netting claim; I.R.C. § 6621(d); jurisdiction over a claim for interest on an overpayment under I.R.C. § 6611; “same taxpayer” within the meaning of I.R.C. § 6621(d)

OPINION AND ORDER

LETTOW, Judge.

Plaintiff, Ford Motor Company (“Ford”), brings suit to recover interest that the gov ernment, acting through the Internal Revenue Service (“IRS”), allegedly owes as a result of Ford’s overpayment of taxes. This is an interest netting case, Ford seeks to balance the interest it owed and paid on underpayments of taxes with interest received from the IRS on overpayments.…