Sunoco, Inc. and Subsidiaries - Page 10

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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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