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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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