- -5
Interest assessed as of 9/18/73 32,903.58
Penalties and lien fee assessed 39,967.34
Total liability 149,310.80
Petitioner's payment on 9/18/73 218,292.77
Less refund on 10/15/73 (20,250.28)
Net payments 198,042.49
Total overpayment 48,731.69
Interest on overpayment 137,446.10
Total payment to petitioner 186,177.79
Petitioner contends that respondent was not entitled to
offset the additions to tax against the overpayment, on the basis
that the period of limitations for collection of the additions to
tax had expired before November 13, 1989, when petitioner states
the collection of the additions to tax were made. Petitioner
computed the interest reported on his return as follows:
Total payment to petitioner 186,177.79
Less overpayment per decision (81,054.21)
Balance 105,123.58
Math error (488.58)
Interest reported per return 104,635.00
On March 17, 1993, respondent mailed a notice of deficiency
to petitioner for the year 1989, which stated that petitioner
received $137,446 in interest income in the taxable year 1989,
rather than the amount of $104,635 of interest income reported by
petitioner on his Federal income tax return for 1989.
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Last modified: May 25, 2011