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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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