- 54 - reduced to $62,225 and then $32,225). Dombrowski requested “audit assistance”, which he received from George Guzzardo (Guzzardo), an appeals auditor in respondent’s San Diego office, in determining whether the Thompsons were entitled to the requested interest. Guzzardo determined that the Thompsons’ $63,000 remittance on June 17, 1987, was an advance payment rather than a cash bond. The distinction is important: An advance payment resulting in an overpayment entitles the taxpayer to interest on the overpayment; conversely, a cash bond does not earn interest. Having concluded that the previously refunded $62,225 was an advance payment, Guzzardo determined that the Thompsons were entitled to additional interest of $31,511.17 as of July 31, 1993. Dombrowski did his own computations, and then asked Jean Samuels (Samuels), an experienced appeals auditor, to check his and Guzzardo’s figures. Samuels advised that in the main she agreed with both Guzzardo’s and Dombrowski’s calculations. Relatively small differences in their results were attributable to their use of different dates for the accrual of interest.24 On September 17, 1993, Dombrowski sent Bakutes a memorandum requesting approval to refund the interest on the Thompsons’ 24Samuels saw that the refund included some previously deducted interest, thus producing tax benefit income, but stated in her memorandum to Dombrowski, “Most taxpayers would probably either not know or not remember to include this [tax benefit income] in income, since they won’t get a Form 1099 for it.”Page: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
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