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(4) a detailed interest calculation which determined the
estate’s total Federal deficiency interest deduction as
$209,943.54; and
(5) Form 3623, Statement of Account. For simplicity, the
following table is an extraction of the information therein
contained:
Tax Interest
Revised liability $385,747.17 --
Assessment (tax on return) 60,164.54 --
Tax Court assessment (5/12/98) 564,429.87 $410,848.76
Total assessments 624,594.41 --
(Decrease) in assessment (238,847.24)
Revised liability 385,747.17
Payments
Payment with return (7/12/91) 60,164.54
Credit transfer 1992 (4/15/93) 63,052.00
Advance payment1 (3/31/98) 501,377.87 144,947.89
Total payments 624,594.41
(Overpayment) (238,847.24)
1Advance payment totaling $646,325.76 received on Mar. 31,
1998. Of the total payment, $501,377.87 was applied towards
the additional tax assessment, and $144,947.89 was applied
towards the additional interest assessment made on May 12,
1998.
The interest referred to in this document is interest on the
underpayment of tax that accrued prior to the estate’s payment of
$646,325.76 on March 31, 1998. Hereafter, we refer to interest
accrued during that period as “underpayment interest”. See
Sunoco, Inc. & Subs. v. Commissioner, 122 T.C. 88 (2004).
On May 6, 2002, after our final decision, respondent abated
$180,564.04 of the previously assessed underpayment interest and
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