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and underpayment interest computed by both parties for each
of the years in issue:
Overpayment Underpayment Total
1979 Appendix 1 -$6,346,670 $1,353,083
Respondent -4,304,396 1,948,026
Difference -2,042,274 -594,943 -$2,637,217
1981 Appendix 2 -48,785,132 -0-
Respondent -11,626,105 231,936
Difference -37,159,027 -231,936 -37,390,963
1983 Appendix 3 -5,759,613 -0-
Respondent -3,317,982 24,970
Difference -2,441,631 -24,970 -2,466,601
In considering the issues raised by respondent’s
motion, it is important to note that the interest computed
at any particular time is based upon the outstanding
balance in petitioner’s account. An interest factor is
applied to that balance for the number of days that elapsed
before the date of the next event that changed the account
balance, or before the date of a change in the rate of
interest. If the effective date of a transaction were
changed, then that would not only cause the account balance
to change; it would also cause the amount of interest, and
possibly the kind of interest (i.e., underpayment or
overpayment interest), computed on that balance to change.
Furthermore, the aggregate amounts of underpayment and
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