Second Circuit: Exxon Mobil Entitled to Retrospective Interest Netting

The Second Circuit Court of Appeals has affirmed the decision of the Tax Court holding that Exxon Mobil is entitled to net interest for periods of overlapping underpayments and overpayments even where the statute of limitations for one “leg” of the overlapping periods has expired.

Congratulations to the taxpayer’s lead counsel and fellow blogger, Alan Horowitz, and our friend on the brief, Kevin Kenworthy.

Read the entire opinion here:
Exxon Mobil v. Commissioner, No. 11-2814 (2d Cir. August 8, 2012)

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