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STATE FARM MUT. AUTO. INS. CO. & SUBS. v. COMMR.

Docket No. 1859-01.

126 T.C. 28 (2006)

126 T.C. No. 2

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 17, 2006.

Attorney(s) appearing for the Case

Jerome B. Libin, James V. Heffernan, and Mary E. Monahan, for petitioner.

Robert Morrison and Jan E. Lamartine, for respondent.

OPINION

GOEKE, Judge:

Before us is petitioner's motion under Rule 2611 seeking a higher rate of interest on petitioner's overpayment. The difference between petitioner's interest computation method and respondent's method stems from a difference of view regarding the effect of a 1994 amendment to section 6621(a)(1), the so-called GATT amendment. That amendment reduced the rate...

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