Exxon Mobil Corporation and Affiliated Companies, f.k.a. Exxon Corporation and Affiliated Companies v. Commissioner

OPINION

Haines, Judge:

These consolidated cases are before the Court on respondent’s motion to dismiss for lack of jurisdiction, petitioners’ motion for partial summary judgment under sections 7481(c) and 6621(d) seeking a net interest rate of zero on equivalent underpayments and overpayments in Federal income taxes for overlapping periods preceding July 22, 1998, and respondent’s cross-motion for partial summary judgment in opposition to petitioners’ motion.

The issues presented are: (1) Whether this Court has jurisdiction under section 7481(c) to resolve petitioners’ section 6621(d)…