Court of Federal Claims supports taxpayer on interest-netting issue

Washington National Tax Services
In a taxpayer-favorable decision, the U.S. Court of Federal Claims recently held, in Magma Power Company v. United States, that the interest-netting provisions of section 6621(d) applied to (1) a separate 1993 underpayment of Magma Power and (2) 1995 to 1998 overpayments of the consolidated group that Magma Power joined in 1995, to the extent that the group’s overpayments were attributable to Magma Power.

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