State Farm Mut. Auto. Ins. Co. v. Comm'r
United States Tax Court
P filed a Motion Pursuant to Rule 261 to Redetermine Interest on Overpayment. The issue raised in P's motion is whether accrued interest on P's overpayment as of Dec. 31, 1994, is subject to the regular rate of interest or the lower rate of interest provided by sec. 6621(a)(1), I.R.C., beginning on Jan. 1, 1995 (the GATT rate). R's position that the GATT rate applies was previously sustained by the Court of Federal Claims and the Court of Appeals for the Federal Circuit in…
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P filed a Motion Pursuant to Rule 261 to Redetermine Interest on Overpayment. The issue raised in P's motion is whether accrued interest on P's overpayment as of Dec. 31, 1994, is subject to the regular rate of interest or the lower rate of interest provided by sec. 6621(a)(1), I.R.C., beginning on Jan. 1, 1995 (the GATT rate). R's position that the GATT rate applies was previously sustained by the Court of Federal Claims and the Court of Appeals for the Federal Circuit in GE v United States, 384 F.3d 1307 (Fed. Cir. 2004), affg. in part and remanding in part 56 Fed. Cl. 488 (2003). See also…
1Opinion of the Court
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
State Farm Mut. Auto. Ins. Co. v. Comm'r
No. 1859-01
United States Tax Court
126 T.C. 28; 2006 U.S. Tax Ct. LEXIS 2; 126 T.C. No. 2;
January 17, 2006, Filed
State Farm Mut. Auto. Ins. Co. v. Commissioner, 105 Fed. Appx. 67, 2004 U.S. App. LEXIS 13600 (2004)
P filed a Motion Pursuant to Rule 261 to Redetermine Interest on
Overpayment. The issue raised in P's motion is whether accrued
interest on P's overpayment as of Dec. 31, 1994, is subject to
the regular rate of interest or the…
2Cases cited6 opinions
- General Electric Company and Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2004
- General Electric Co. v. United StatesUnited States Court of Federal Claims · 2003
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2002
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2006
- State Farm Mutual Automobile Insurance v. CommissionerCourt of Appeals for the Seventh Circuit · 2004
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