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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.
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