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overpayment interest computed for the year would also
change.
For example, if petitioner’s computation for 1979 were
changed to reflect respondent’s position with respect to
one of the issues raised by petitioner for that year, the
effective date of the carryback of a foreign tax credit of
$3,876,645 from 1981, then the resulting recomputation of
the account is shown in appendix 4. As shown in appendix
4, making that one change causes the aggregate amount of
underpayment interest to be increased to $2,021,767 (see
appendix 4) from $1,353,083 (see appendix 1), and it causes
the aggregate amount of overpayment interest to be reduced
to $5,272,357 (see appendix 4) from $6,346,670 (see
appendix 1). This illustrates the fact that the
computations are interrelated, and underpayment interest
and overpayment interest cannot be computed separately.
Discussion
This Court exercises only such jurisdiction as is
conferred on it by statute. See sec. 7442. By statute,
we are authorized to redetermine the amount of a
deficiency for a particular taxable period as to which the
Commissioner issued a notice of deficiency and the taxpayer
petitioned the Court for review. See secs. 6212, 6213, and
6214; Monge v. Commissioner, 93 T.C. 22, 27 (1989). As to
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