Energy East Corp. v. United States

OPINION AND ORDER

WILLIAMS, Judge.

In this action, Plaintiff seeks to recoup interest in the amount of $2,715,006.92, which it claims in connection with certain overpay-ments and underpayments of taxes. Plaintiff claims that it is entitled to an interest rate of zero under a statutory provision that allows “netting” of interest where there are equivalent underpayments and overpayments by the same taxpayer. This matter comes before the Court on the parties’ cross-motions for summary judgment.

Plaintiff, Energy East Corporation (“Energy East”) and its subsidiaries, Central Maine Power Company…