General Electric Company and Subsidiaries v. United States

BRYSON, Circuit Judge.

This federal income tax case concerns the amount of interest the government owes the taxpayer, General Electric Company and Subsidiaries (“GE”), based on GE’s overpayment of its taxes for 1978. A statute enacted in 1994 provided that as of January 1, 1995, the rate of interest paid on corporate tax overpayments in excess of $10,000 would be reduced from its previous level. GE argues that the lower rate does not apply in this case because by 1995 GE’s overpayment of taxes for 1978 had already been repaid and only the accrued interest on the overpayment remained…