Court of Appeals for the Federal Circuit August 12, 2004, 12-1241 (Federal National Mortgage Association v. United States)

MICHEL, Circuit Judge.

Federal National Mortgage Association (“FNMA”) filed this tax refund action to recover overpayment interest, invoking a statutory “Special Rule” that permits taxpayers to request retroactive application of an Internal Revenue Code provision requiring the Internal Revenue Service (“IRS”) to apply a zero net interest rate to overlapping periods of mutual taxpayer and IRS