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HILL v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 794-18.

T.C. Memo. 2021-121

ALBERT G. HILL, III, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed October 25, 2021.

Attorney(s) appearing for the Case

Ajay Gupta , Guinevere M. Moore , and Elizabeth A. Yablonicky , for petitioner.

Ashley Vaughan Targac , William Walter Kiessling , and William Benjamin McClendon , for respondent.

MEMORANDUM OPINION

Currently before the Court is petitioner's motion to redetermine interest under section 7481(c) and Rule 261.1 In 2012 petitioner remitted to the Internal Revenue Service (IRS or respondent) a check for $10,263,750, designating the remittance as a "deposit" to be applied toward...

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