Interest Netting May Be Worth More Than You Think

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It may be worth your while to reexamine the benefit of IRC Sec. 6621(d)’s interest netting to the amount of interest paid to and received from the IRS. Recent court decisions have expanded the meaning of “same taxpayer” by allowing…

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Statute of Limitations for Interest May be Much Longer Than You Think

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The statute of limitations (SOL) for an interest claim runs two, three, or six years depending on whether the interest you’re claiming arose out of an underpayment or overpayment. Understanding which limitations period applies is an essential step in protecting…

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The Court of Appeals for the Federal Circuit denies refund of additional interest requested by the Ford Motor Company (Nov. 13, 2018)

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The Court of Appeals for the Federal Circuit has affirmed a decision by the U.S. Court of Federal Claims (Fed Cl, 2017-1 USTC ¶550,239) which denied the Ford Motor Company’s (Ford) claim that the Parent and its wholly owned Foreign…

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