Exxon Mobil Corp. v. Comm'r
United States Tax Court
The Tax Reform Act of 1986, Pub. L. 99-514, sec. 1511(a), 100 Stat. 2744, modified sec. 6621, I.R.C., to increase the interest required to be paid by taxpayers to the Government on underpayments to a higher rate than the Government was required to pay taxpayers on overpayments. This resulted in taxpayers' having to pay interest to the Government even when underpayments were offset by overpayments; i.e., when no tax was due.
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The Tax Reform Act of 1986, Pub. L. 99-514, sec. 1511(a), 100 Stat. 2744, modified sec. 6621, I.R.C., to increase the interest required to be paid by taxpayers to the Government on underpayments to a higher rate than the Government was required to pay taxpayers on overpayments. This resulted in taxpayers' having to pay interest to the Government even when underpayments were offset by overpayments; i.e., when no tax was due. In 1998 Congress enacted sec. 6621(d), I.R.C., and an uncodified special rule set forth in the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L.…
1Opinion of the Court
EXXON MOBIL CORPORATION AND AFFILIATED COMPANIES, f.k.a. EXXON CORPORATION AND AFFILIATED COMPANIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Exxon Mobil Corp. v. Comm'r
Docket Nos. 18618-89, 18432-90.
United States Tax Court
136 T.C. 99; 2011 U.S. Tax Ct. LEXIS 5; 136 T.C. No. 5;
February 3, 2011, Filed
Exxon Mobil Corp. v. Comm'r, 484 F.3d 731, 2007 U.S. App. LEXIS 8275 (5th Cir., 2007)
An order will be issued granting petitioners' motion for partial summary judgment and denying respondent's motion to dismiss for lack of jurisdiction and cross-motion for partial summary judgment.
2Cases cited34 opinions
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- Dolan v. United States Postal ServiceSupreme Court of the United States · 2006
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