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EXXON MOBIL CORP. & COS. v. COMMISSIONER

Docket Nos. 18618-89, 18432-90, 23331-95.

126 T.C. 36 (2006)

126 T.C. No. 3

EXXON MOBIL CORPORATION AND AFFILIATED COMPANIES, F.K.A. EXXON CORPORATION AND AFFILIATED COMPANIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 17, 2006.

Attorney(s) appearing for the Case

Robert L. Moore II, Thomas D. Johnston, and Kevin Kenworthy, for petitioners.

Robert M. Morrison, for respondent.

OPINION

SWIFT, Judge:

This matter is before us on petitioners' motions under section 7481(c) and Rule 261 for the Court to determine the correct amount of overpayment interest due petitioners.1

The primary issue presented is whether petitioners' cumulative accrued overpayment interest balance outstanding on December 31, 1994, of approximately $1.6 billion (relating to petitioners' consolidated Federal income taxes...

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