Hallmark Cards, Incorporated and Subsidiaries - Page 3

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          unreduced deficiency and the interest thereon.  Respondent has              
          refunded the 1987 overpayment resulting from the carryback, a               
          portion of overpayment interest thereon, and a portion of                   
          previously assessed deficiency interest for that year.                      
               Petitioner's motion to redetermine interest alleges that               
          respondent erred in computing interest on that portion of the               
          previously existing deficiency that was satisfied by the                    
          application of the foreign tax carryback.  Respondent computed              
          interest on such deficiency during the period beginning with the            
          due date for petitioner's 1987 tax return and ending with the due           
          date of the 1989 return, March 15, 1990.  It is petitioner's                
          position that, in any event, interest on the deficiency should              
          stop accruing as of December 31, 1989, the end of the taxable               
          year in which the carryback arose.  Petitioner's position on                
          these issues is identical to that of the taxpayer in Intel Corp.            
          & Consol. Subs. v. Commissioner, 111 T.C. 90 (1998), in which we            
          denied the taxpayer's motion to redetermine interest.                       
               Petitioner adopts an indecisive approach to support its                
          motion to withdraw.  Thus, it does not directly seek to persuade            
          us to decide that we do not have jurisdiction, apparently                   
          assuming that we would decide the issue unfavorably to                      
          petitioner, see Bankamerica Corp. v. Commissioner, 109 T.C. 1, 7            
          (1997).  Further, it is apparent that petitioner's concern over             
          our jurisdiction became a critical element in petitioner's                  
          strategy only after our decision in Intel Corp. & Consol. Subs.             




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