Exxon Mobil Corp. & Affiliated Companies v. Commissioner

W. EUGENE DAVIS, Circuit Judge:

Overpayments of tax to the Internal Revenue Service earn interest (compounded daily) from the date paid to the IRS until refunded to the taxpayer. Effective January 1, 1995, section 6621(a)(1) of the Internal Revenue Code was amended to provide that “to the extent that an overpayment of tax by a corporation for any taxable period ... exceeds $10,000,” the rate at which the government pays interest on the overpayment is reduced. The issue in this case is whether the Tax Court correctly held that interest that had accrued 1 on taxpayer’s overpayments of tax as of…