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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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