Exxon Mobil Corp. v. Comm'r
United States Tax Court
Held: Under secs. 6611, 6621(a)(1) and 6622, petitioners' outstanding Dec. 31, 1994, cumulative accrued overpayment interest balance of $ 1.6 billion relating to the years involved herein accrues further compound interest after Dec. 31, 1994, at the reduced interest rate applicable to large corporate overpayments, not at the regular interest rate. GE v. United States, 56 Fed. Cl. 488 (2003) , affd. 384 F.3d 1307 (Fed. Cir. 2004) , and State Farm Mut. Auto. Ins.
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Held: Under secs. 6611, 6621(a)(1) and 6622, petitioners' outstanding Dec. 31, 1994, cumulative accrued overpayment interest balance of $ 1.6 billion relating to the years involved herein accrues further compound interest after Dec. 31, 1994, at the reduced interest rate applicable to large corporate overpayments, not at the regular interest rate. GE v. United States, 56 Fed. Cl. 488 (2003) , affd. 384 F.3d 1307 (Fed. Cir. 2004) , and State Farm Mut. Auto. Ins. Co. v. Commissioner, 126 T.C.__, 2006 U.S. Tax Ct. LEXIS 2 (2006) , followed. Petitioners' claim for an additional $ 450 million in…
1Opinion of the Court
OPINION
Swift, Judge:
This matter is before us on petitioners’ motions under section 7481(c) and Rule 261 for the Court to determine the correct amount of overpayment interest due petitioners.1
The primary issue presented is whether petitioners’ cumulative accrued overpayment interest balance outstanding on December 31, 1994, of approximately $1.6 billion (relating to petitioners’ consolidated Federal income taxes for 1979 through 1985) accrues compound interest thereafter until paid to petitioners at the regular corporate overpayment interest rate, as petitioners contend, or at the reduced…
2Cases cited11 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Kaiser Aluminum & Chemical Corp. v. BonjornoSupreme Court of the United States · 1990
- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
- General Electric Company and Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2004
- Anderson v. Comm'rUnited States Tax Court · 2004
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Exxon Mobil Corp. & Affiliated Companies v. CommissionerCourt of Appeals for the Fifth Circuit · 2007
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2006
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2011
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2006
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2011
3 more not listed; retrieve them via the Exa API.