-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.Page: Previous 1 2 3 4
Last modified: May 25, 2011