Legal Opinion
State Farm Mutual Automobile Insurance Company and Subsidiaries v. Commissioner
United States Tax Court
Decided January 17, 2006No. 1859-01Unknown
1Opinion of the Court
126 T.C. No. 2
UNITED STATES TAX COURT STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1859-01. Filed January 17, 2006. P filed a Motion Pursuant to Rule 261 to Redetermine Interest on Overpayment. The issue raised in P’s motion is whether accrued interest on P’s overpayment as of Dec. 31, 1994, is subject to the regular rate of interest or the lower rate of interest provided by sec. 6621(a)(1), I.R.C., beginning on Jan. 1, 1995 (the GATT rate). R’s position that the GATT rate applies was previously…
2Cases cited5 opinions
- General Electric Company and Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2004
- General Electric Co. v. United StatesUnited States Court of Federal Claims · 2003
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2002
- State Farm Mutual Automobile Insurance v. CommissionerCourt of Appeals for the Seventh Circuit · 2004
- State Farm Mut. Auto. Ins. Co. v. Comm'rUnited States Tax Court · 2006