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payment of $144,947.89, leaving an unpaid balance of $64,995.65).
The prior interest assessment in this case does not reflect the
actual interest liability due and owing. When it was assessed,
this interest was beyond our jurisdiction because the case was in
a deficiency situation. Our authority to address this unpaid
assessment of interest is now limited to section 7481(c) and Rule
261, neither of which are before us.
V. Rule 155
The present issue originates with this Court’s execution of
the decision document in question. The opinion was based on a
computation which the parties agreed was in conformity with this
Court’s opinion after remand pursuant to Rule 155(a). The Court
executed the decision relying on the parties’ agreement without
reviewing the agreed computation. A review of the computation
would have revealed that the overpayment amount was not reduced
by interest liabilities but that an interest deduction was
permitted for the anticipated payment of Federal interest of
$64,995.65 on the estate tax deficiency.
The estate represented to the Court that the computation
submitted was in conformity with the Court’s opinion and the
estate also represented that the interest in the amount of
$64,995.65 was deductible, explicitly acknowledging that such
interest would be paid by offset against the overpayment of tax
shown in the agreed Rule 155 computation. The Court relied upon
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