Sunoco, Inc. and Subsidiaries - Page 7

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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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