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EXXON MOBIL CORP. v. COMMISSIONER

Docket Nos. 18618-89, 18432-90.

136 T.C. 99 (2011)

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 February 3, 2011.

Attorney(s) appearing for the Case

Kevin L. Kenworthy and Alan I. Horowitz, for petitioners.

R. Scott Shieldes, for respondent.

OPINION

HAINES, Judge:

These consolidated cases are before the Court on respondent's motion to dismiss for lack of jurisdiction, petitioners' motion for partial summary judgment under sections 7481(c) and 6621(d) seeking a net interest rate of zero on equivalent underpayments and overpayments in Federal income taxes for overlapping periods preceding July 22, 1998, and respondent's cross-motion for partial summary...

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