Detroit Free Press:  Ford Sues to Collect Interest; $445 Million Is Sought from IRS, by Sarah A. Webster:

Ford Motor Co. is suing the federal government, saying the Internal Revenue Service owes it nearly half a billion dollars in interest for overpayments on corporate taxes.

In a lawsuit filed on Thursday in U.S. District Court in Detroit, the struggling Dearborn automaker says it is owed $445,292,207 for miscalculations of interest on taxes for the calendar years 1983 to 1989, 1992 and 1994, which were generally more profitable times for Ford. …

[T]he dispute at hand involves a disagreement about how the interest should be calculated and how much interest Ford is actually owed. "The IRS’ calculation of … overpayment interest is not a simple matter of taking the tax underpayment … and computing interest on that amount," the lawsuit says. "Rather, the IRS recomputes the taxpayer’s account for the specific tax year by sorting all of the transactions in order of the dates they are deemed to be effective and computing interest on the account balance as it is affected from transaction to transaction."