Overseas Thread Industries, Ltd. v. United States

OPINION

BUSH, Judge.

This matter is before the court on the parties’ cross motions for summary judgment. During the taxable years 1987, 1988, and 1989, the taxpayer-plaintiff, Overseas Thread, Inc. (OTI) made overpayments to the Internal Revenue Service (IRS). The IRS refunded the amount of the overpay-ments, but the parties differ on the amount of statutory interest due OTI. Therefore, the sole issue for the court to determine is the date that interest starts to accrue, under section 6611 of the Internal Revenue Code (I.R.C.) and the relevant Treasury Regulations.1 The court rules that section…