General Electric Co. v. United States

OPINION

ALLEGRA, Judge.

This refund suit presents a straightforward, but nonetheless difficult, question of law: whether plaintiff is entitled to additional interest on statutory interest that had accrued as of December 31, 1994, with respect to a 1978 overpayment of tax. Resolving this question of first impression requires the court to interpret a 1994 amendment to section 6621(a)(1) of the Internal Revenue Code of 1986 (26 U.S.C.) (“the Code”).2 Specifically, this court must determine whether the “interest on interest” owed plaintiff accrued at the standard rate provided by section 6621(a)(1)…