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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’s
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Last modified: May 25, 2011