Marsh & McLennan Companies, Inc. v. United States

OPINION

MILLER, Judge.

This case is before the court after argument on cross-motions for summary judgment. The issue for decision is whether the taxpayer is entitled to interest on overpay-ments of federal income tax for 1985 and 1986 to the date on which each overpayment was applied to satisfy a later-arising liability or to the date on which the tax was due for the year generating the liability.

*141FACTS

The facts are not disputed. Marsh & McLennan Co., Inc. (“plaintiff’), overpaid its 1985 federal income taxes by $275,139.00 (the “1985 Overpayment”) and overpaid its 1986 federal income taxes by…