- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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