- 54 - overpayment, and, in order to do so, we have jurisdiction to redetermine the correct amount of the interest on their original underpayments. Petitioners assign a number of errors to respondent’s interest computations. We consider each of petitioners’ contentions in turn. A. Start Dates The parties agree that June 7, 1982, the date respondent issued to petitioners their 1981 refund, is the correct start date for 1981. The parties disagree as to what are the correct start dates for 1979 and 1982. 1. 1979 Relying on Avon Products, Inc. v. United States, 588 F.2d 342 (2d Cir. 1978), petitioners contend that June 28, 1982, the date respondent issued to petitioners a refund for 1979 plus interest thereon, is the correct start date for 1979 because petitioners did not have the use of respondent’s money before that date. Relying on Rev. Proc. 94-60, 1994-2 C.B. 774, respondent contends that January 1, 1982, the date respondent began to accrue interest on petitioners’ overpayment, is the correct start date for 1979. Respondent maintains that this approach “comports with” Avon Products, Inc. v. United States, supra. We agree with respondent’s conclusion.Page: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
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