Intel Corporation and Consolidated Subsidiaries - Page 3

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               The parties agree that, for the taxable years 1979 and 1980,           
          petitioner had foreign tax carrybacks from 1981 and 1982 as                 
          follows:                                                                    
                                             Year                                     
               Year Used      Amount         Originated                               
               1979           $5,015,830     1981                                     
               1980           753,462        1981                                     
                              4,574,958      1982                                     
          The parties disagree as to the effect, if any, of these                     
          carrybacks on the calculation of interest on the deficiencies for           
          1979 and 1980.  The principal issue for decision is whether                 
          interest accrues on the portion of a deficiency that is                     
          eliminated by such carrybacks.  If it does accrue, when does it             
          end, i.e., at the close of the taxable year of the carryback or             
          on the due date for the filing of the tax return for that year?             
          We direct our attention, in the first instance, to the principal            
          issue.                                                                      
               Section 6601(a) provides that interest shall be paid on the            
          amount of tax not paid on or before the last date prescribed for            
          payment for the period from such last date to the date paid.  The           
          last date prescribed for payment of income tax is generally the             
          due date for filing the return without regard to any extension of           
          time for filing.  Sec. 6601(b)(1).                                          
               "In general, interest liability is determined under section            
          6601 synchronically, looking at the period during which interest            





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