- 64 -
733 F.2d 435, 436 (6th Cir. 1984) and cases there cited, affg.
T.C. Memo. 1982-735; Pesch v. Commissioner, 78 T.C. 100, 117-118,
120 n.29 (1982); see also Ideal Rlty. Co. v. United States, 561
F.2d 1123, 1125 (4th Cir. 1977).
We hold for respondent that interest on the 1982
underpayment begins to accrue on April 15, 1983. See our
comments, supra, as to the period for which respondent did not
pay interest on the overpayment.
B. Asserted Accounting Errors
1. $2.44
Petitioners contend on opening brief that “$2.44 was paid
5/19/85 not 5/19/86". Respondent acknowledges on answering brief
that, on an interest computation as to 1979 prepared for trial,
the “$2.44 was listed in error on exhibit 82-R as May 19, 1996
instead of May 19, 1986.” Respondent insists that “such item was
paid on May 19, 1986. (Ex. 3-J).”
This dispute affects the “bottom line” only to the extent of
1 year’s worth of interest on $2.44, plus the effect of
compounding the interest on that 1 year’s worth of interest.
See, e.g., Dang v. Commissioner, 259 F.3d at 206.
The only evidence on this matter that we have found in the
record is respondent’s transcript of account, which shows the
$2.44 as “credit applied 05-19-86 from Form 1040 tax period Dec
1985". In the absence of (1) any restrictions on the use of this
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