Phillip Purer Winifred Purer v. United States

LEAVY, Circuit Judge:

In this appeal from the district court’s denial of a claim for refund of allegedly overpaid income taxes, the appellants contend that the Internal Revenue Service misinterpreted a statute that changed the manner in which interest on deficiencies was calculated, and was estopped from claiming a portion of the accumulated interest on the appellants’ tax deficiency. We review de novo, see First American Title Ins. Co. v. United States, 848 F.2d 969, 970 (9th Cir.1988), and we affirm.

Prior to January 1, 1983, the Internal Revenue Service imposed simple statutory interest on…