United States v. Alan Francis Beane

HULL, Circuit Judge:

Pursuant to a certification of direct appeal and an order of this Court, the government directly appeals the decision of the Bankruptcy Court regarding the interest due from Alan Francis Beane for the taxable year 1998. The government claims a prior Tax Court decision never addressed the interest issue. The government also disputes how and when interest on Beane’s 1998 tax deficiency should be calculated. To understand the interest issue, we must recount in detail the procedural history of the case.

I. BACKGROUND

A. 2002 Notice of Deficiency

On May 9, 2002, the United States…