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GARWOOD IRRIGATION CO. v. COMMISSIONER

Docket No. 1459-03.

126 T.C. 233 (2006)

126 T.C. No. 12

GARWOOD IRRIGATION COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 1, 2006.

Attorney(s) appearing for the Case

Donald F. Wood and Benjamin M. Leff, for petitioner.

Richard T. Cummings and Michael W. Bentley, for respondent.

OPINION

GOEKE, Judge:

Petitioner has filed a motion under Rule 2611 seeking a redetermination of overpayment interest. The issue is the appropriate rate of interest on petitioner's overpayment.

The underlying facts of this case are set out in detail in Garwood Irrigation Co. v. Commissioner, T.C. Memo. 2004-195, and are incorporated herein by this reference. Petitioner...

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