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stipulated exhibit and (2) any evidence contradicting the
correctness of this transcript of account entry, we conclude that
it is more likely than not that the correct date is May 19, 1986,
rather than May 19, 1985.
We hold for respondent on this issue.
2. $894.09 or $887.33
Petitioners contend on opening brief that “$894.09 (rather
than 887.33) was paid on 12/26/86.” Respondent acknowledges on
answering brief that, on an interest computation as to 1979
prepared for trial, “the amount of a credit for a payment on
December 26, 1985, was listed incorrectly on exhibit 83-R as
$887.33 instead of $894.09.”
This agreement between the parties, which is consistent with
the information in respondent’s transcript of account for 1979,
is to be given effect in the computation under Rule l55.
C. Sec. 6621(c) Rate
On April 29, 1985, respondent assessed an additional $1,360
tax liability on account of 1979 and an additional $87 tax
liability on account of 1981. Apparently, interest was accrued
on these items at the section 6621(c) rate. The parties have
stipulated that these assessed additional tax liabilities are not
subject to the section 6621(c) rate.
On August 18, 1995, respondent assessed an additional $1,144
tax liability on account of 1981. Apparently, interest was
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