No. 03-5173.

417 F.3d 1375 (2005)

PACIFIC GAS AND ELECTRIC COMPANY and PG & E Corporation, Plaintiffs-Appellants, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

August 10, 2005.

Attorney(s) appearing for the Case

Craig Martin Buchsbaum, Pacific Gas and Electric Company, of San Francisco, California, argued for plaintiffs-appellants.

Andrea R. Tebbets, Attorney, Tax Division, Appellate Section, United States Department of Justice, of Washington, DC, argued for defendant-appellee. With her on the brief were Eileen J. O'Connor, Assistant Attorney General and Richard Farber, Attorney.

Before MICHEL, Chief Judge, ARCHER, Senior Circuit Judge, and BRYSON, Circuit Judge.

ARCHER, Senior Circuit Judge.

Pacific Gas and Electric Company and PG & E Corporation (collectively "PGE") appeal the United States Court of Federal Claims' judgment that the Internal Revenue Service ("IRS" or "Service") properly offset statutory interest that was erroneously paid to PGE ("erroneous interest") with respect to the tax year 1982, against a later refund of tax and interest determined to be due PGE for the same tax year. Pac. Gas & Elec. Co...

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