Federal National Mortgage Association v. United States

MICHEL, Circuit Judge.

Federal National Mortgage Association (“FNMA”) filed this tax refund action to recover overpayment interest, invoking a statutory “Special Rule” that permits taxpayers to request retroactive application of an Internal Revenue Code provision requiring the Internal Revenue Service (“IRS”) to apply a zero net interest rate to overlapping periods of mutual taxpayer and IRS indebtedness. On the parties’ cross-motions for partial summary judgment, the United States Court of Federal Claims held that FNMA was entitled to the interest it claimed. Fed. Nat’l Mortgage Ass’n v.…