United States Court of Federal Claims April 2, 2003, No. 00-369T (Federal National Mortgage Ass'n v. United States)

OPINION

WIESE, Judge.

This tax refund suit is before the court after oral argument on cross-motions for partial summary judgment. At issue is whether the taxpayer is entitled to application of a zero net interest rate to overlapping periods of mutual indebtedness between the taxpayer and the government in connection with tax years 1974, 1975, 1983, and 1986.