Sunoco, Inc. and Subsidiaries - Page 4

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                            Respondent’s   Petitioner’s                               
             Year              Totals       Computation    Overpayment                
             1979  Underpayment  $1,948,026 1$1,353,083   -$594,943                   
                  interest                                                            
             Overpayment   -4,304,396       1-6,346,670   -2,042,274                  
                  interest                                                            
                  Total     -2,356,370      -4,993,587    -2,637,217                  
             1981   Underpayment     231,936-0-            -231,936                    
                  interest                                                            
                  Overpayment  -11,626,105 2-48,785,132   -37,159,027                 
                  interest                                                            
                  Total     -11,394,169     -48,785,132   -37,390,963                 
             1983  Underpayment    24,970  -0-            -24,970                     
                  interest                                                            
             Overpayment   -3,317,982       3-5,759,613   -2,441,631                  
                  interest                                                            
                  Total     -3,293,012      -5,759,613    -2,466,601                  
                  1 As of Dec. 14, 1993.                                              
                  2 As of Mar. 3, 1997.                                               
                  3 As of June 14, 1993.                                              

                  Attached to respondent’s motion to dismiss is the                   
             affidavit of an employee of the Internal Revenue Service,                
             a former technical analyst, who is knowledgeable about                   
             the preparation of interest computations on Federal tax                  
             liabilities and who has had extensive experience with                    
             the computerized records of the Internal Revenue Service,                
             referred to as transcripts of account, which reflect                     
             account activity, such as assessments, payments, credits,                
             and the like, for particular taxpayers.  The Government’s                
             affidavit includes, as an exhibit, a document that was                   
             prepared on behalf of petitioner entitled “Listing of                    
             Differences-–Sun’s Interest Computations v. IRS’ Interest                





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