Court Rules Against Ford Motor Company’s Complaint for $445 Million in Tax Overpayment Interest
A federal court in Detroit has denied Ford Motor Company’s $445 million complaint against the United States for alleged tax overpayment interest.
As explained in the court’s opinion, Ford had sent the Internal Revenue Service (IRS) a cash bond to stop the running of underpayment interest on potential corporate income tax liabilities relating to ongoing IRS audits. Ford later asked that the deposits be converted to tax payments.
The IRS eventually determined that Ford had overpaid its taxes, and was entitled to a refund. Because the IRS calculated tax overpayment interest from the date of conversion to a tax payment and not from the date of the deposit, the IRS refunded overpayment interest from the date that Ford requested that its deposits be treated as payments. Ford claimed that the interest should have been calculated from the date it originally remitted the deposits.
In granting the United States’ motion for judgment on the pleadings, Judge Patrick J. Duggan held that the IRS’s interpretation of the overpayment interest statute was reasonable and that "Ford’s challenges to the government’s treatment of its deposits fail as a matter of law."
Acting Assistant Attorney General John A. DiCicco commended trial attorney Christine S. Hooks on her handling of the case.
As explained in the court’s opinion, Ford had sent the Internal Revenue Service (IRS) a cash bond to stop the running of underpayment interest on potential corporate income tax liabilities relating to ongoing IRS audits. Ford later asked that the deposits be converted to tax payments.
The IRS eventually determined that Ford had overpaid its taxes, and was entitled to a refund. Because the IRS calculated tax overpayment interest from the date of conversion to a tax payment and not from the date of the deposit, the IRS refunded overpayment interest from the date that Ford requested that its deposits be treated as payments. Ford claimed that the interest should have been calculated from the date it originally remitted the deposits.
In granting the United States’ motion for judgment on the pleadings, Judge Patrick J. Duggan held that the IRS’s interpretation of the overpayment interest statute was reasonable and that "Ford’s challenges to the government’s treatment of its deposits fail as a matter of law."
Acting Assistant Attorney General John A. DiCicco commended trial attorney Christine S. Hooks on her handling of the case.
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