SUNOCO, INC. & SUBS. v. COMMISSIONER

Docket No. 19631-97.

122 T.C. 88 (2004)

122 T.C. No. 4

SUNOCO, INC. AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 4, 2004.


Attorney(s) appearing for the Case

Robert L. Moore II, Thomas D. Johnston, and Majorie A. Burnett, for petitioner.

John A. Guarnieri, Craig Connell, and Keith L. Gorman, for respondent.


OPINION

WHALEN, Judge:

This case is before the Court to decide respondent's motion to dismiss for lack of subject matter jurisdiction filed with regard to certain claims petitioner made in an amendment to its petition. The issue raised by respondent's motion is whether this Court lacks jurisdiction under section 6512(b) to consider petitioner's claims for overpayment to the extent that they involve so-called overpayment interest, as described below...

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