- 13 - February 20, 1996, petitioners have not overpaid the interest due on the $6,054 tax deficiency that respondent assessed as a computational adjustment on October 23, 1995, regardless of whether such interest is computed under the normal rate prescribed in section 6621(a)(2) or under the increased rate prescribed in section 6621(c). See Greene v. Commissioner, T.C. Memo. 1995-105. Petitioner's contention that the $3,240.60 paid on February 20, 1996, represents the full amount of the interest due on the tax deficiency of $6,054 is incorrect. Petitioner's argument is based on the erroneous assumption that the interest due on the deficiency of $6,054, arising from the disallowance of his distributive share of the loss reported by Irving & Co., is computed from April 15, 1987 (the due date of petitioners' 1986 tax return) to March 18, 1991 (the date that petitioners executed a waiver of restrictions as to assessment and collection in docket No. 11547-90). To the contrary, the stipulated decision entered in docket No. 11547-90, and the waiver of restrictions on assessment and collection which petitioners executed in connection with that decision, concerned adjustments to petitioners' 1986 tax liability wholly independent of the partnership adjustments underlying the instant proceeding. In this light, it is evident that the waiver does not toll thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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