INTRODUCTION

Feb 11, 2013 · (January 13, 2006); Non Acq. 2006 -26 I.R.B. 1147, AOD 2006-26-02, 2006 WL 2830795. In that case, the Federal Circuit held that because overpayment interest is not an assessable amount, overpayment interest that was erroneously paid to the taxpayer more than two years before the litigation could not be offset against additional claims for ... ................
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