info@ustax.cpa |+ 353 1 6834066-    ( Morrison Chambers, 32 Nassau Street, Suite 35, Dublin D02 P2N6 )

The Fourth Circuit seemed split Tuesday on whether Bank of America should be able to use its tax overpayments to offset interest on tax underpayments by companies that merged into it, with one judge pressing the government to respond to what he described as the bank’s “common sense” argument in the $163 million case.