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
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.1
The issues presented are: (1) Whether this Court has jurisdiction under section 7481(c) to resolve petitioners’ section 6621(d)…
2Cases cited33 opinions
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. MitchellSupreme Court of the United States · 1983
- Block v. North Dakota Ex Rel. Board of University & School LandsSupreme Court of the United States · 1983
- United States v. White Mountain Apache TribeSupreme Court of the United States · 2003
- Dolan v. United States Postal ServiceSupreme Court of the United States · 2006
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3Cited by3 opinions
- Exxon Mobil Corp. & Affiliated Cos. v. CommissionerCourt of Appeals for the Second Circuit · 2012
- Pfizer Inc. & Subsidiaries v. United StatesCourt of Appeals for the Second Circuit · 2019
- Exxon Mobil Corp. v. Comm'rUnited States Tax Court · 2011