- 7 - Interest is computed on the balance of petitioner’s account as follows. If the account balance is positive at the time interest is computed, i.e., indicating an interim underpayment, then the interest on that balance is so- called underpayment interest and is computed under section 6601(a) (see col. I). If the account balance is negative at the time interest is computed, i.e., indicating an interim overpayment, then the interest on that balance is so-called overpayment interest and is computed under section 6611(a) (see col. H). The number of days and the interest factors used in the interest computation are shown in each appendix. The amounts of underpayment interest and overpayment interest computed in these appendixes correlate with the amounts computed by petitioner and verified by respondent, except that there is a difference of less than $1 in 1981. The parties agree that for each of the years in issue, the balance of petitioner’s account with the Internal Revenue Service comprises the transactions recorded in the column entitled “Other Events” in the appropriate appendix. They also agree that the correct dollar amount of each of those transactions is the dollar amount shown in the appendix. Neither party has raised an issue about the method of computing interest, as reflected in petitioner’sPage: 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