-41-
rather than on April 15, 2000.
Petitioners are correct when they state in their brief that
this issue is not properly before the Court at this time.
Moreover, we note that, pursuant to section 6601(a), interest
begins to run on “the last date prescribed for payment” of the
tax and, pursuant to section 6151(a), an extension of time for
filing an income tax return does not extend the time for paying
the tax due.
Based upon the foregoing,
Decision will be entered for
respondent.
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