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occurred.1 As recently as his August 28, 2006, status report,
respondent essentially admitted that the IRS made mistakes
regarding the computation of petitioner’s interest, including,
but not limited to, quoting petitioner an incorrect payoff figure
and sending petitioner an allegedly “erroneous” refund on account
of respondent’s erroneous calculations and a keystroke error by
an IRS employee.
Another example is contained in respondent’s opening brief
and his August 28, 2006, status report. In his opening brief,
respondent alleged that as of January 24, 2006, the amount of
1 The Court of Appeals stated:
the IRS seemed equally unsure about several basic and
crucial facts. The parties' confusion is
understandable; the relevant timeline and tax amounts
have been reconstructed using photocopied forms,
computer screen printouts, and dot-matrix printouts of
tax account balances. Many of these records have no
supporting explanation (and therefore are inscrutable
to any non-employee of the IRS), many are from time
periods that are not the same, and even the documents
that are from similar time periods often contain
amounts that are inexplicably contradictory.
* * * * * * *
This “21-R” report is a computer screen printout of
approximately twenty lines of abbreviations,
alphanumeric codes, dates, and digits that are
indecipherable to us without additional explanation. *
* * [Wright v. Commissioner, 381 F.3d 41, 44, 45 (2d
Cir. 2004), vacating and remanding T.C. Memo. 2002-
312.]
The Court of Appeals also noted that it had “doubts inspired by
the IRS’s past calculation errors against Wright’s account”. Id.
at 45.
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