United States Court of Federal Claims October 18, 2004, No. 01-280T (AT & T Corp. & Subsidiaries v. United States)

OPINION

REGINALD W. GIBSON, Senior Judge.

I. INTRODUCTION

This case comes before the court after oral argument on cross-motions for summary judgment, filed by the parties pursuant to RCFC 56. Before us is a complex and arcane issue pertaining solely to the calculation of overpayment interest, pursuant to 26 U.S.C. § 6611.