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To take account of respondent’s concessions and the
foregoing,
Decision will be entered
under Rule 155.26
26 The parties have stipulated as follows:
The parties agree that the methodology to use in
determining the correct amount of interest for each year in
issue is first to calculate the interest that accrues on the
balance due (giving effect to all payments, credits, and
abatements shown on the transcripts - exhibit 3-J) from the
appropriate start date determined by the Court to the date
interest was paid for that year with no interest accruing
during the waiver periods, agreed abatement periods, such
further abatement periods as determined by the Court, and
such other periods of no interest accrual determined by the
Court at issue in the case. This accrued interest is then
subtracted from the total interest assessed. If the
difference is a positive number, the difference is an
overassessment of interest which should be abated. Since
the total interest assessed has been paid, such
overassessment will constitute an overpayment which should
be refunded to petitioners.
This stipulation is to be given effect in the Rule 155
computations.
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