-4-
interest on any amount of unpaid taxes, with interest beginning
to accrue on such unpaid taxes as of the last date prescribed for
payment. Sec. 6601(a).5 Petitioner has therefore raised no
valid arguments that the determination by Appeals was an abuse of
discretion, and we sustain that determination. All other
arguments by the parties have been considered, and those not
discussed herein have been rejected as meritless. Accordingly,
Decision will be entered
for respondent.
5 Respondent concedes that interest accrues on related
penalties and additions to tax from Feb. 3, 2003, when respondent
assessed petitioner’s 1995 and 1996 deficiencies.
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Last modified: May 25, 2011