Federal National Mortgage Ass'n v. United States

OPINION

WIESE, Judge.

This is a tax refund suit. Plaintiff, the Federal National Mortgage Association (“Fannie Mae”), seeks to recover additional statutory interest in the amount of $4,940,328 on an overpayment of federal income tax for the taxable year ending December 31, 1974. The case is now before the court on cross-motions for summary judgment following a decision of the Federal Circuit, entered August 12, 2004, reversing this court’s grant of partial summary judgment in plaintiffs favor and remanding the matter for a determination as to whether the statute of limitations applicable to…