- 4 - agreed underpayments. Nevertheless, respondent did not credit the overpayments against the underpayments. By checks dated July 20, 1995, and August 4, 1995, in the respective amounts of $11,203,987 and $1,767,273, respondent refunded the overpayment for 1984. Included in the refund was interest calculated at the overpayment rate specified in section 6621(a)(1). By check dated September 5, 1995, in the amount of $62,798, respondent refunded the overpayment for 1987 with interest calculated in the same manner. On or about July 26, 1995, petitioner executed a Form 870-AD reflecting the partial settlement of its tax liabilities for the years 1988 through 1991. The Form 870-AD showed agreed underpayments of $909,763 for 1988, $911,371 for 1989, $9,513 for 1990, and $613,513 for 1991, or an aggregate of $2,444,160 of agreed underpayments. The Form 870-AD also contained the following statement: "The taxpayer reserves the right to challenge the interest calculations made by the Internal Revenue Service with respect to all years/periods covered by this agreement." Respondent accepted the Form 870-AD on August 17, 1995, and on or about August 30, 1995, assessed the agreed tax and mailed two Notices of Tax Due relating to the agreed underpayments. Included in the amount of tax due was interest in the amount of $2,003,589.91 calculated at the underpayment rate specified in section 6621(a)(2) and (c).Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011