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Petitioners contend that, under section 6601(c), interest
should have stopped accruing on January 13, 1995, 30 days after
they transmitted to Rowland the executed decision document, which
included a waiver of restrictions on assessment pursuant to
section 6213(d). They argue that “any suggestion that Respondent
has the right to decide when to file stipulated decision
documents” is a “tortured interpretation” of section 6601(c).
Respondent maintains that all of respondent’s interest
computations comport with section 6601(c), and that interest
properly stopped accruing on June 1, 1995, 30 days after the
decision document was entered by the Court.
The language of the parties’ agreed-upon waiver itself
resolves this issue. See also, e.g., Pallottini v. Commissioner,
90 T.C. 498, 502-503 (1988), where we focused on the text of the
document (in that case, a statute) itself, rather than general
rules, in order to determine the document’s effect.
The parties stipulated as follows:
effective upon entry of this decision by the Court, the
petitioners waive the restriction contained in I.R.C.
6213(a) prohibiting assessment and collection of the
deficiencies in income tax and additions to tax (plus
statutory interest) until the decision of the Tax Court has
become final.
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