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computation and respondent’s verification, or the
percentage interest factors used therein.
The parties disagree about the dates on which many
of the transactions should be recorded in petitioner’s
account. The substantive issues raised by petitioner’s
amendment to petition and list of differences all involve
the date on which each of certain of the agreed trans-
actions is recorded in petitioner’s account for purposes of
computing interest. In general, petitioner contends that
the items noted in its list of differences are transactions
that were recorded in petitioner’s account on dates that
caused either too much underpayment interest under section
6601 to be charged or too little overpayment interest under
section 6611 to be allowed on the account.
For example, with respect to 1979, petitioner contends
that the amount of underpayment interest respondent charged
in 1979, $1,948,026, is $594,943 too high when compared to
petitioner’s computation of the amount of underpayment
interest, $1,353,083, shown in appendix 1. Similarly,
petitioner contends that the amount of overpayment interest
respondent allowed for 1979, $4,304,396, is $2,042,274 too
low when compared to petitioner’s computation of the amount
of overpayment interest, $6,346,670, shown in appendix 1.
The following schedule compares the overpayment interest
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