- 4 -
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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011