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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