United States Federal Circuit

In a suit concerning the amount of interest the government owes for corporate tax overpayment, rejection of plaintiff's claim is reversed and the case is remanded to determine whether plaintiff is entitled to any additional interest attributable to the first $10,000 of its original overpayment for 1978.

Appellate Information

• Decided 09/27/2004
• Published 09/27/2004

Judges

• BRYSON, Circuit Judge., Before RADER, BRYSON, and GAJARSA, Circuit Judges.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Robert L. Moore, II, Miller & Chevalier, Chartered, of Washington, DC, argued for plaintiff-appellant.   With him on the brief were Thomas D. Johnston and Alan I. Horowitz.   Of counsel on the brief were Patricia M. Lacey and Laurence A. Hoch, General Electric Co. and Subsidiaries, of Albany, New York., Jerome B. Libin, Sutherland Asbill & Brennan LLP, of Washington, DC, for amici curiae.   With him on the brief were Steuart H. Thomsen, Mary E. Monahan, and James V. Heffernan.


• For Appellees:
  
• Charles Bricken, Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellee.   With him on the brief were Eileen J. O'Connor, Assistant Attorney General, and Thomas J. Clark, Attorney.