William F. Urbano and Flota L. Urbano - Page 17

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          included therein.  Although we understand petitioners to contend            
          credibly that they believed that they were entering into an                 
          agreement to settle their 1993 liability when they executed the             
          Form 4549-CG, such a unilateral belief on their part does not               
          satisfy the requirements of section 7121.  Nor were the                     
          requirements of that section met simply because respondent                  
          accepted petitioners’ check in the amount listed on Form 4549-CG            
          as the total tax, penalties, and interest for 1993 and the other            
          3 years under audit.  See Parks v. Commissioner, 33 T.C. 298                
          (1959); see also Bowling v. United States, 510 F.2d 112 (5th Cir.           
          1975); United States v. Hardy, 299 F.2d 600 (4th Cir. 1962).                
               We also disagree with petitioners’ second argument, that the           
          assessment for the disputed interest is invalid in that they were           
          not informed about that interest before it was assessed.                    
          Petitioners concede that the assessment was timely; we find no              
          provision in the Internal Revenue Code that would require any               
          such prior notification.                                                    
               Interest on a Federal income tax liability generally begins            
          to accrue from the last date prescribed for payment of that tax             
          and continues to accrue, compounding daily, until payment is                
          made.  See secs. 6601(a), 6622.  In the case of an income tax               
          deficiency that is later reduced or eliminated by a carryback of            
          an NOL, section 6601(d)(1) authorizes the Commissioner to collect           
          deficiency interest from taxpayers such as petitioners whose                

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