Sunoco, Inc. and Subsidiaries - Page 3

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             to errors allegedly made by respondent “in calculating the               
             interest on underpayments and overpayments arising out of                
             the settled issues”.  The amended petition alleges that in               
             calculating interest respondent used “numerous incorrect                 
             starting and ending dates for the running of interest”                   
             and “numerous incorrect dates in applying payments and                   
             credits and making transfers to other accounts” and that                 
             “respondent failed to credit or refund the correct amount                
             of interest on petitioner’s overpayments.”  In addition,                 
             the amended petition alleges that “respondent did not use                
             netting principles when calculating the interest balances”               
             and “in addition to the overpayments referenced above,                   
             petitioner seeks overpayments attributable to the                        
             calculation of interest utilizing netting principles.”                   
             In general, according to the amended petition, for each                  
             of the years in issue, the interest respondent charged                   
             on “underpayments” under section 6601 was too high,                      
             and the interest respondent allowed with respect to                      
             “overpayments” under section 6611 was too low.                           
                  The amended petition asserts that the overpayment                   
             for each of the years in issue is as follows:                            

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Last modified: May 25, 2011