Google is suing the IRS for an $83.5 million refund, the company claims it is owed, related to stock warrants granted to AOL back in 2004. The news comes from Bloomberg, which reports:

The IRS erred in disallowing a $238.6 million deduction claimed for the difference between the price AOL paid to exercise a warrant for Google stock and the value of the shares, according to the complaint in U.S. Tax Court.

“Google’s actual cost for issuing the AOL warrant was $238,667,835, which equaled the spread between the $21,642,985 it received from AOL to exercise the AOL warrant and $260 million in value” of the stock, Google said in the complaint.

The company evidently made note of its intent to file a complaint against the IRS in an SEC filing back in January, without getting into specifics.

Liz Gannes at All Things D got this statement from a Google spokesperson :

“We filed a petition challenging an outstanding issue from our 2003/2004 tax assessment. This is a domestic issue related to stock warrants and we hope to have it resolved soon.”

It’s an interesting turn of events, considering that Google is often accused of not paying enough taxes.