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FEDERAL NAT. MORTG. ASS'N v. U.S.

No. 03-5162.

379 F.3d 1303 (2004)

FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff-Appellee, v. UNITED STATES, Defendant-Appellant.

United States Court of Appeals, Federal Circuit.

DECIDED: August 12, 2004.

Attorney(s) appearing for the Case

Alan I. Horowitz, Miller & Chevalier, Chartered, of Washington, DC, argued for plaintiff-appellee. With him on the brief was Thomas D. Johnston.

Ellen Page Delsole, Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellant. With her on the brief were Eileen J. O'Connor, Assistant Attorney General, Richard T. Morrison, Deputy Assistant Attorney General, and Richard Farber, Attorney.

Before MICHEL, SCHALL, and DYK, Circuit Judges.

MICHEL, Circuit Judge.

Federal National Mortgage Association ("FNMA") filed this tax refund action to recover overpayment interest, invoking a statutory "Special Rule" that permits taxpayers to request retroactive application of an Internal Revenue Code provision requiring the Internal Revenue Service ("IRS") to apply a zero net interest rate to overlapping periods of mutual taxpayer and IRS indebtedness. On the parties' cross-motions for partial summary judgment...

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