Sunoco, Inc. and Subsidiaries - Page 5

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             Computations.”  This exhibit is referred to herein as                    
             petitioner’s list of differences.  It is petitioner’s list               
             of each of the errors that respondent allegedly made in                  
             computing interest.                                                      
                  There is also attached to the Government’s affidavit                
             petitioner’s computation of the amount of interest that                  
             would have accrued with respect to petitioner’s account for              
             each of the years in issue if the differences described in               
             petitioner’s list were taken into account.  Finally, there               
             are attached to the Government’s affidavit three schedules               
             that were prepared on behalf of respondent to verify the                 
             accuracy of petitioner’s computations.  We note that,                    
             while we have been provided with petitioner’s interest                   
             computations and respondent’s verification of petitioner’s               
             computations, we have not been supplied with respondent’s                
             computations of interest.                                                
                  On the basis of the information in the record, we                   
             have prepared three appendixes in which we have reproduced               
             petitioner’s computation of interest for each of the tax                 
             years in issue, 1979, 1981, and 1983.  These appendixes are              
             attached hereto as appendixes 1, 2, and 3, respectively.                 
                  Each appendix is in the nature of a transcript of                   
             petitioner’s account with the Internal Revenue Service for               
             one of the years in issue; i.e., 1979, 1981, or 1983.  It                

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