Mobil Corp. v. United States

OPINION

HODGES, Judge.

Mobil Corporation sues to recover interest it allegedly overpaid for tax years 1974 and 1975 in the amounts of $817,531 and $628,645 respectively. Plaintiff contends that the Internal Revenue Service (IRS) calculated the deficiency interest that plaintiff owed, using a method inconsistent with its long-standing practice for calculating such interest. Defendant argues that plaintiff did not file a claim for refund of the disputed amounts within the applicable statutory time period, and moves to dismiss the complaint for lack of jurisdiction. We grant defendant’s motion to…