Computation of Interest on IFTA Audit Deficiencies   [author:
Sharon R. Paxton]  On May 2, 2012, a three-judge panel of the
Commonwealth Court ruled in Southern Pines Trucking v.
Commonwealth, 352 F.R. 2008, that an interstate trucking company
was not entitled to credit in an IFTA audit for interest on tax
overpayments made to various jurisdictions.  After an IFTA
audit, the Pennsylvania Department of Revenue issued a Notice of
Determination to Southern Pines identifying overpayments and
underpayments by jurisdiction.  The Notice imposed a net tax
deficiency of $17,840.25 ($83,918.19 less $66,077.94 of credits
for net tax overpayments made to other jurisdictions), plus
interest of $18,615.24 (computed on the pre-credit deficiency of
$83,918.19).  Southern Pines contended that the Department had
improperly charged interest on amounts owed to jurisdictions
where tax was underpaid, without giving any credit for interest
on the company's tax overpayments to other jurisdictions.  Under
IFTA, when a motor carrier's