- 10 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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