Court:
U.S. Court of Appeals
(Fourth Circuit)

Amicus Issue:
Whether Section 6621(d) of the Internal Revenue Code (which provides that when the “same taxpayer” has offsetting underpayments and overpayments such that the net tax is zero, the interest rate on underpayments and overpayments is zero as well) applies when a company with an underpayment merges with a company with an equivalent overpayment.

Counsel of Record:
Covington & Burling LLP

Lauren Willard Zehmer
Kandyce Jayasinghe
Daniel G. Randolph

Other Amici:
U.S. Chamber of Commerce
The Business Roundtable
American Bankers Assoc.