- 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’ InterestPage: 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