-CITE-
    26 USC CHAPTER 67 - INTEREST                                01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST

-HEAD-
                           CHAPTER 67 - INTEREST                       

-MISC1-
    Subchapter                                                  Sec.(!1)
    A.      Interest on underpayments                               6601 
    B.      Interest on overpayments                                6611
    C.      Determination of interest rate; compounding of
             interest                                               6621
    D.      Notice requirements                                     6631

                                AMENDMENTS                            
      1998 - Pub. L. 105-206, title III, Sec. 3308(b), July 22, 1998,
    112 Stat. 745, added item for subchapter D.
      1982 - Pub. L. 97-248, title III, Sec. 344(b)(3)(B), Sept. 3,
    1982, 96 Stat. 636, inserted "; compounding of interest" after
    "rate" in item for subchapter C.
      1975 - Pub. L. 93-625, Sec. 7(d)(5), Jan. 3, 1975, 88 Stat. 2115,
    added item for subchapter C.

-FOOTNOTE-
    (!1) Section numbers editorially supplied.


-End-


-CITE-
    26 USC Subchapter A - Interest on Underpayments             01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter A - Interest on Underpayments

-HEAD-
                 SUBCHAPTER A - INTEREST ON UNDERPAYMENTS             

-MISC1-
    Sec.                                                     
    6601.       Interest on underpayment, nonpayment, or extensions of
                 time for payment, of tax.                            
    6602.       Interest on erroneous refund recoverable by suit.     
    6603.       Deposits made to suspend running of interest on
                 potential underpayments, etc.                        

                                AMENDMENTS                            
      2004 - Pub. L. 108-357, title VIII, Sec. 842(b), Oct. 22, 2004,
    118 Stat. 1599, added item 6603.

-End-



-CITE-
    26 USC Sec. 6601                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter A - Interest on Underpayments

-HEAD-
    Sec. 6601. Interest on underpayment, nonpayment, or extensions of
      time for payment, of tax

-STATUTE-
    (a) General rule
      If any amount of tax imposed by this title (whether required to
    be shown on a return, or to be paid by stamp or by some other
    method) is not paid on or before the last date prescribed for
    payment, interest on such amount at the underpayment rate
    established under section 6621 shall be paid for the period from
    such last date to the date paid.
    (b) Last date prescribed for payment
      For purposes of this section, the last date prescribed for
    payment of the tax shall be determined under chapter 62 with the
    application of the following rules:
      (1) Extensions of time disregarded
        The last date prescribed for payment shall be determined
      without regard to any extension of time for payment or any
      installment agreement entered into under section 6159.
      (2) Installment payments
        In the case of an election under section 6156(a) (!1) to pay
      the tax in installments - 

          (A) The date prescribed for payment of each installment of
        the tax shown on the return shall be determined under section
        6156(b),(!1) and
          (B) The last date prescribed for payment of the first
        installment shall be deemed the last date prescribed for
        payment of any portion of the tax not shown on the return.
      (3) Jeopardy
        The last date prescribed for payment shall be determined
      without regard to any notice and demand for payment issued, by
      reason of jeopardy (as provided in chapter 70), prior to the last
      date otherwise prescribed for such payment.
      (4) Accumulated earnings tax
        In the case of the tax imposed by section 531 for any taxable
      year, the last date prescribed for payment shall be deemed to be
      the due date (without regard to extensions) for the return of tax
      imposed by subtitle A for such taxable year.
      (5) Last date for payment not otherwise prescribed
        In the case of taxes payable by stamp and in all other cases in
      which the last date for payment is not otherwise prescribed, the
      last date for payment shall be deemed to be the date the
      liability for tax arises (and in no event shall be later than the
      date notice and demand for the tax is made by the Secretary).
    (c) Suspension of interest in certain income, estate, gift, and
      certain excise tax cases
      In the case of a deficiency as defined in section 6211 (relating
    to income, estate, gift, and certain excise taxes), if a waiver of
    restrictions under section 6213(d) on the assessment of such
    deficiency has been filed, and if notice and demand by the
    Secretary for payment of such deficiency is not made within 30 days
    after the filing of such waiver, interest shall not be imposed on
    such deficiency for the period beginning immediately after such
    30th day and ending with the date of notice and demand and interest
    shall not be imposed during such period on any interest with
    respect to such deficiency for any prior period. In the case of a
    settlement under section 6224(c) which results in the conversion of
    partnership items to nonpartnership items pursuant to section
    6231(b)(1)(C), the preceding sentence shall apply to a
    computational adjustment resulting from such settlement in the same
    manner as if such adjustment were a deficiency and such settlement
    were a waiver referred to in the preceding sentence.
    (d) Income tax reduced by carryback or adjustment for certain
      unused deductions
      (1) Net operating loss or capital loss carryback
        If the amount of any tax imposed by subtitle A is reduced by
      reason of a carryback of a net operating loss or net capital
      loss, such reduction in tax shall not affect the computation of
      interest under this section for the period ending with the filing
      date for the taxable year in which the net operating loss or net
      capital loss arises.
      (2) Foreign tax credit carrybacks
        If any credit allowed for any taxable year is increased by
      reason of a carryback of tax paid or accrued to foreign countries
      or possessions of the United States, such increase shall not
      affect the computation of interest under this section for the
      period ending with the filing date for the taxable year in which
      such taxes were in fact paid or accrued, or, with respect to any
      portion of such credit carryback from a taxable year attributable
      to a net operating loss carryback or a capital loss carryback
      from a subsequent taxable year, such increase shall not affect
      the computation of interest under this section for the period
      ending with the filing date for such subsequent taxable year.
      (3) Certain credit carrybacks
        (A) In general
          If any credit allowed for any taxable year is increased by
        reason of a credit carryback, such increase shall not affect
        the computation of interest under this section for the period
        ending with the filing date for the taxable year in which the
        credit carryback arises, or, with respect to any portion of a
        credit carryback from a taxable year attributable to a net
        operating loss carryback, capital loss carryback, or other
        credit carryback from a subsequent taxable year, such increase
        shall not affect the computation of interest under this section
        for the period ending with the filing date for such subsequent
        taxable year.
        (B) Credit carryback defined
          For purposes of this paragraph, the term "credit carryback"
        has the meaning given such term by section 6511(d)(4)(C).
      (4) Filing date
        For purposes of this subsection, the term "filing date" has the
      meaning given to such term by section 6611(f)(4)(A).
    (e) Applicable rules
      Except as otherwise provided in this title - 
      (1) Interest treated as tax
        Interest prescribed under this section on any tax shall be paid
      upon notice and demand, and shall be assessed, collected, and
      paid in the same manner as taxes. Any reference to this title
      (except subchapter B of chapter 63, relating to deficiency
      procedures) to any tax imposed by this title shall be deemed also
      to refer to interest imposed by this section on such tax.
      (2) Interest on penalties, additional amounts, or additions to
        the tax
        (A) In general
          Interest shall be imposed under subsection (a) in respect of
        any assessable penalty, additional amount, or addition to the
        tax (other than an addition to tax imposed under section
        6651(a)(1) or 6653 or under part II of subchapter A of chapter
        68) only if such assessable penalty, additional amount, or
        addition to the tax is not paid within 21 calendar days from
        the date of notice and demand therefor (10 business days if the
        amount for which such notice and demand is made equals or
        exceeds $100,000), and in such case interest shall be imposed
        only for the period from the date of the notice and demand to
        the date of payment.
        (B) Interest on certain additions to tax
          Interest shall be imposed under this section with respect to
        any addition to tax imposed by section 6651(a)(1) or 6653 or
        under part II of subchapter A of chapter 68 for the period
        which - 
            (i) begins on the date on which the return of the tax with
          respect to which such addition to tax is imposed is required
          to be filed (including any extensions), and
            (ii) ends on the date of payment of such addition to tax.
      (3) Payments made within specified period after notice and demand
        If notice and demand is made for payment of any amount and if
      such amount is paid within 21 calendar days (10 business days if
      the amount for which such notice and demand is made equals or
      exceeds $100,000) after the date of such notice and demand,
      interest under this section on the amount so paid shall not be
      imposed for the period after the date of such notice and demand.
    (f) Satisfaction by credits
      If any portion of a tax is satisfied by credit of an overpayment,
    then no interest shall be imposed under this section on the portion
    of the tax so satisfied for any period during which, if the credit
    had not been made, interest would have been allowable with respect
    to such overpayment. The preceding sentence shall not apply to the
    extent that section 6621(d) applies.
    (g) Limitation on assessment and collection
      Interest prescribed under this section on any tax may be assessed
    and collected at any time during the period within which the tax to
    which such interest relates may be collected.
    (h) Exception as to estimated tax
      This section shall not apply to any failure to pay any estimated
    tax required to be paid by section 6654 or 6655.
    (i) Exception as to Federal unemployment tax
      This section shall not apply to any failure to make a payment of
    tax imposed by section 3301 for a calendar quarter or other period
    within a taxable year required under authority of section 6157.
    (j) 2-percent rate on certain portion of estate tax extended under
      section 6166
      (1) In general
        If the time for payment of an amount of tax imposed by chapter
      11 is extended as provided in section 6166, then in lieu of the
      annual rate provided by subsection (a) - 
          (A) interest on the 2-percent portion of such amount shall be
        paid at the rate of 2 percent, and
          (B) interest on so much of such amount as exceeds the 2-
        percent portion shall be paid at a rate equal to 45 percent of
        the annual rate provided by subsection (a).

      For purposes of this subsection, the amount of any deficiency
      which is prorated to installments payable under section 6166
      shall be treated as an amount of tax payable in installments
      under such section.
      (2) 2-percent portion
        For purposes of this subsection, the term "2-percent portion"
      means the lesser of - 
          (A)(i) the amount of the tentative tax which would be
        determined under the rate schedule set forth in section 2001(c)
        if the amount with respect to which such tentative tax is to be
        computed were the sum of $1,000,000 and the applicable
        exclusion amount in effect under section 2010(c), reduced by
          (ii) the applicable credit amount in effect under section
        2010(c), or
          (B) the amount of the tax imposed by chapter 11 which is
        extended as provided in section 6166.
      (3) Inflation adjustment
        In the case of estates of decedents dying in a calendar year
      after 1998, the $1,000,000 amount contained in paragraph (2)(A)
      shall be increased by an amount equal to - 
          (A) $1,000,000, multiplied by
          (B) the cost-of-living adjustment determined under section
        1(f)(3) for such calendar year by substituting "calendar year
        1997" for "calendar year 1992" in subparagraph (B) thereof.

      If any amount as adjusted under the preceding sentence is not a
      multiple of $10,000, such amount shall be rounded to the next
      lowest multiple of $10,000.
      (4) Treatment of payments
        If the amount of tax imposed by chapter 11 which is extended as
      provided in section 6166 exceeds the 2-percent portion, any
      payment of a portion of such amount shall, for purposes of
      computing interest for periods after such payment, be treated as
      reducing the 2-percent portion by an amount which bears the same
      ratio to the amount of such payment as the amount of the 2-
      percent portion (determined without regard to this paragraph)
      bears to the amount of the tax which is extended as provided in
      section 6166.
    (k) No interest on certain adjustments
          For provisions prohibiting interest on certain adjustments in
        tax, see section 6205(a).

-SOURCE-
    (Aug. 16, 1954, ch. 736, 68A Stat. 817; Pub. L. 85-866, title I,
    Secs. 66(c), 83(a)(1), 84(a), title II, Sec. 206(e), Sept. 2, 1958,
    72 Stat. 1658, 1663, 1664, 1685; Pub. L. 87-61, title II, Sec.
    203(c)(2), June 29, 1961, 75 Stat. 126; Pub. L. 87-834, Sec.
    2(e)(3), Oct. 16, 1962, 76 Stat. 972; Pub. L. 88-571, Sec. 3(d),
    Sept. 2, 1964, 78 Stat. 858; Pub. L. 89-384, Sec. 1(f), Apr. 8,
    1966, 80 Stat. 104; Pub. L. 90-225, Sec. 2(e), Dec. 27, 1967, 81
    Stat. 731; Pub. L. 91-53, Sec. 2(e), Aug. 7, 1969, 83 Stat. 92;
    Pub. L. 91-172, title I, Sec. 101(j)(49), title V, Sec. 512(e)(3),
    Dec. 30, 1969, 83 Stat. 531, 641; Pub. L. 92-178, title VI, Sec.
    601(d)(3), Dec. 10, 1971, 85 Stat. 559; Pub. L. 93-406, title II,
    Sec. 1016(a)(17), Sept. 2, 1974, 88 Stat. 930; Pub. L. 93-625, Sec.
    7(a)(2)(A), (b)(1), Jan. 3, 1975, 88 Stat. 2115; Pub. L. 94-452,
    Sec. 3(c)(3), Oct. 2, 1976, 90 Stat. 1514; Pub. L. 94-455, title
    XIII, Sec. 1307(d)(2)(H), title XVI, Sec. 1605(b)(10), title XIX,
    Secs. 1906(a)(34), (b)(13)(A), title XX, Sec. 2004(b), title XXI,
    Sec. 2107(g)(2)(C), Oct. 4, 1976, 90 Stat. 1728, 1755, 1829, 1834,
    1867, 1904; Pub. L. 95-30, title II, Sec. 202(d)(4)(C), May 23,
    1977, 91 Stat. 150; Pub. L. 95-628, Sec. 8(c)(2), Nov. 10, 1978, 92
    Stat. 3632; Pub. L. 96-223, title I, Sec. 101(f)(7), Apr. 2, 1980,
    94 Stat. 253; Pub. L. 97-248, title III, Secs. 344(b)(1),
    346(c)(2), Sept. 3, 1982, 96 Stat. 635, 637; Pub. L. 98-76, title
    II, Sec. 231(b)(2)(D), Aug. 12, 1983, 97 Stat. 429; Pub. L. 98-369,
    div. A, title I, Sec. 158(a), title II, Sec. 211(b)(26), title IV,
    Sec. 412(b)(7), title VII, Sec. 714(n)(1), July 18, 1984, 98 Stat.
    696, 757, 792, 963; Pub. L. 99-514, title XIV, Sec. 1404(c)(3),
    title XV, Secs. 1511(c)(11), 1512(a), 1564(a), Oct. 22, 1986, 100
    Stat. 2714, 2745, 2746, 2762; Pub. L. 100-203, title X, Sec.
    10301(b)(5), Dec. 22, 1987, 101 Stat. 1330-429; Pub. L. 100-647,
    title I, Secs. 1015(b)(2)(C), 1018(u)(42), title VI, Sec.
    6234(b)(1), title VII, Sec. 7106(c)(5), Nov. 10, 1988, 102 Stat.
    3569, 3592, 3736, 3774; Pub. L. 101-239, title VII, Sec.
    7721(c)(8), Dec. 19, 1989, 103 Stat. 2400; Pub. L. 101-508, title
    XI, Sec. 11801(c)(20)(B), Nov. 5, 1990, 104 Stat. 1388-528; Pub. L.
    104-168, title III, Sec. 303(a), (b)(1), July 30, 1996, 110 Stat.
    1458; Pub. L. 105-34, title V, Secs. 501(e), 503(a), (c)(2), (3),
    title X, Sec. 1055(a), title XII, Sec. 1242(a), Aug. 5, 1997, 111
    Stat. 846, 852, 853, 944, 1029; Pub. L. 105-206, title III, Sec.
    3301(b), July 22, 1998, 112 Stat. 741; Pub. L. 109-135, title IV,
    Sec. 409(a)(2), Dec. 21, 2005, 119 Stat. 2635.)


-STATAMEND-
    ADJUSTMENT OF DOLLAR AMOUNT USED IN DETERMINING "2-PERCENT PORTION"
      For adjustment of dollar amount used in determining "2-percent
    portion" for purpose of calculating interest under subsection (j)
    of this section in the case of decedents dying in calendar year
    2007, see section 3.39 of Revenue Procedure 2006-53, set out as a
    note under section 1 of this title.

-REFTEXT-
                            REFERENCES IN TEXT                        
      Section 6156, referred to in subsec. (b)(2), was repealed by Pub.
    L. 108-357, title VIII, Sec. 867(b)(1), Oct. 22, 2004, 118 Stat.
    1622.


-MISC1-
                                AMENDMENTS                            
      2005 - Subsec. (d)(4). Pub. L. 109-135 substituted
    "6611(f)(4)(A)" for "6611(f)(3)(A)".
      1998 - Subsec. (f). Pub. L. 105-206 inserted at end "The
    preceding sentence shall not apply to the extent that section
    6621(d) applies."
      1997 - Subsec. (c). Pub. L. 105-34, Sec. 1242(a), inserted at end
    "In the case of a settlement under section 6224(c) which results in
    the conversion of partnership items to nonpartnership items
    pursuant to section 6231(b)(1)(C), the preceding sentence shall
    apply to a computational adjustment resulting from such settlement
    in the same manner as if such adjustment were a deficiency and such
    settlement were a waiver referred to in the preceding sentence."
      Subsec. (d)(2) to (4). Pub. L. 105-34, Sec. 1055(a), added par.
    (2) and redesignated former pars. (2) and (3) as (3) and (4),
    respectively.
      Subsec. (j). Pub. L. 105-34, Sec. 503(c)(3), substituted "2-
    percent" for "4-percent" in heading.
      Subsec. (j)(1). Pub. L. 105-34, Sec. 503(a), reenacted par.
    heading without change and amended text generally. Prior to
    amendment, text read as follows: "If the time for payment of an
    amount of tax imposed by chapter 11 is extended as provided in
    section 6166, interest on the 4-percent portion of such amount
    shall (in lieu of the annual rate provided by subsection (a)) be
    paid at the rate of 4 percent. For purposes of this subsection, the
    amount of any deficiency which is prorated to installments payable
    under section 6166 shall be treated as an amount of tax payable in
    installments under such section."
      Subsec. (j)(2). Pub. L. 105-34, Sec. 503(a), amended heading and
    text generally. Prior to amendment, text read as follows: "For
    purposes of this subsection, the term '4-percent portion' means the
    lesser of - 
        "(A) $345,800 reduced by the amount of the credit allowable
      under section 2010(a); or
        "(B) the amount of the tax imposed by chapter 11 which is
      extended as provided in section 6166."
      Subsec. (j)(3). Pub. L. 105-34, Sec. 501(e), added par. (3).
    Former par. (3) redesignated (4).
      Subsec. (j)(4). Pub. L. 105-34, Sec. 503(c)(2), substituted "2-
    percent" for "4-percent" wherever appearing.
      Pub. L. 105-34, Sec. 501(e), redesignated par. (3) as (4).
      1996 - Subsec. (e)(2)(A). Pub. L. 104-168, Sec. 303(b)(1),
    substituted "21 calendar days from the date of notice and demand
    therefor (10 business days if the amount for which such notice and
    demand is made equals or exceeds $100,000)" for "10 days from the
    date of notice and demand therefor".
      Subsec. (e)(3). Pub. L. 104-168, Sec. 303(a), substituted
    "specified period" for "10 days" in heading and amended text
    generally. Prior to amendment, text read as follows: "If notice and
    demand is made for payment of any amount, and if such amount is
    paid within 10 days after the date of such notice and demand
    interest under this section on the amount so paid shall not be
    imposed for the period after the date of such notice and demand."
      1990 - Subsec. (b)(2). Pub. L. 101-508 struck out "or 6158(a)"
    after "6156(a)" in introductory provisions, struck out "or 6158(a),
    as the case may be" after "6156(a)" in subpar. (A), and struck out
    at end "For purposes of subparagraph (A), section 6158(a) shall be
    treated as providing that the date prescribed for payment of each
    installment shall not be later than the date prescribed for payment
    of the 1985 installment."
      1989 - Subsec. (e)(2). Pub. L. 101-239 substituted "section
    6651(a)(1) or 6653 or under part II of subchapter A of chapter 68"
    for "section 6651(a)(1), 6653, 6659, 6660, or 6661" in subpars. (A)
    and (B).
      1988 - Subsec. (b)(1). Pub. L. 100-647, Sec. 6234(b)(1), inserted
    "or any installment agreement entered into under section 6159"
    after "time for payment".
      Subsec. (b)(2). Pub. L. 100-647, Sec. 1018(u)(42), made technical
    correction to directory language of Pub. L. 99-514, Sec.
    1404(c)(3), see 1986 Amendment note below.
      Subsec. (e)(2)(A), (B). Pub. L. 100-647, Sec. 1015(b)(2)(C),
    substituted "6653, 6659" for "6659".
      Subsec. (i). Pub. L. 100-647, Sec. 7106(c)(5), struck out "or
    3321" after "3301".
      1987 - Subsec. (h). Pub. L. 100-203 substituted "section 6654 or
    6655" for "section 6154 or 6654".
      1986 - Subsec. (a). Pub. L. 99-514, Sec. 1511(c)(11), substituted
    "the underpayment rate established under section 6621" for "an
    annual rate established under section 6621".
      Subsec. (b)(2). Pub. L. 99-514, Sec. 1404(c)(3), as amended by
    Pub. L. 100-647, Sec. 1018(u)(42), substituted "6156(a) or 6158(a)"
    for "6152(a), 6156(a), or 6158(a)" in introductory provisions and
    "6156(b) or 6158(a)" for "6152(b), 6156(b), or 6158(a)" in subpar.
    (A).
      Subsec. (b)(4), (5). Pub. L. 99-514, Sec. 1512(a), added par. (4)
    and redesignated former par. (4) as (5).
      Subsec. (c). Pub. L. 99-514, Sec. 1564(a), inserted "and interest
    shall not be imposed during such period on any interest with
    respect to such deficiency for any prior period".
      1984 - Subsec. (d)(2)(A). Pub. L. 98-369, Sec. 714(n)(1), made
    technical correction to directory language of Pub. L. 97-248, Sec.
    346(c)(2)(B). See 1982 Amendment note below.
      Subsec. (d)(3), (4). Pub. L. 98-369, Sec. 211(b)(26),
    redesignated par. (4) as (3) and struck out former par. (3) which
    had provided that if the amount of any tax imposed by subtitle A
    was reduced by operation of section 815(d)(5) (relating to
    reduction of policyholders surplus account of life insurance
    companies for certain unused deductions), such reduction in tax
    would not affect the computation of interest under this section for
    the period ending with the last day of the last taxable year to
    which the loss described in section 815(d)(5)(A) was carried under
    section 812(b)(2).
      Subsec. (e)(2). Pub. L. 98-369, Sec. 158(a), in amending par. (2)
    generally, inserted "(other than an addition to tax imposed under
    section 6651(a)(1), 6659, 6660, or 6661)", and added subpar. (B).
      Subsec. (h). Pub. L. 98-369, Sec. 412(b)(7), amended subsec. (h)
    generally, substituting "any estimated tax required to be paid by
    section 6154 or 6654" for "estimated tax required by section 6153
    or section 6154".
      1983 - Subsec. (i). Pub. L. 98-76 inserted "or 3321" after
    "3301".
      1982 - Subsec. (d)(1). Pub. L. 97-248, Sec. 346(c)(2)(A),
    substituted "the filing date for the taxable year" for "the last
    day of the taxable year".
      Subsec. (d)(2)(A). Pub. L. 97-248, Sec. 346(c)(2)(B), as amended
    by Pub. L. 98-369, Sec. 346(c)(2)(B), substituted "the filing date
    for" for "the last day of" in two places.
      Subsec. (d)(4). Pub. L. 97-248, Sec. 346(c)(2)(C), added par.
    (4).
      Subsec. (e). Pub. L. 97-248, Sec. 344(b)(1), struck out par. (2)
    which had provided that no interest under this section was to be
    imposed on the interest provided by this section, and redesignated
    pars. (3) and (4) as (2) and (3), respectively.
      1980 - Subsec. (c). Pub. L. 96-223 substituted "certain excise
    tax cases" for "chapter 41, 42, 43, or 44 tax cases" in heading.
      1978 - Subsec. (d)(2). Pub. L. 95-628, Sec. 8(c)(2)(A),
    substituted in heading "Certain credit carrybacks" for "Investment
    credit carryback", designated existing provision as subpar. (A),
    and in subpar. (A) as so designated, inserted heading "In general"
    and in text extended the application of the provision to credit
    carrybacks, previously limited to investment credit carrybacks,
    included other credit carrybacks, and added subpar. (B).
      Subsec. (d)(4), (5). Pub. L. 95-628, Sec. 8(c)(2)(B), struck out
    pars. (4) and (5) which provided for work incentive program credit
    carrybacks and new employee credit carrybacks, respectively.
      1977 - Subsec. (d)(5). Pub. L. 95-30 added par. (5).
      1976 - Subsec. (b)(2). Pub. L. 94-452 substituted ", 6156(a), or
    6158(a)" for "or 6156(a)" and ", 6156(b), or 6158(a)" for "or
    6156(b)" and inserted requirement that for purposes of subparagraph
    (A), section 6158(a) of this title shall be treated as providing
    that the date prescribed for payment of each installment shall not
    be later than the date prescribed for payment of the 1985
    installment.
      Subsec. (b)(4). Pub. L. 94-455, Sec. 1906(b)(13)(A), struck out
    "or his delegate" after "Secretary".
      Subsec. (c). Pub. L. 94-455, Secs. 1307(d)(2)(H), 1605(b)(10),
    substituted in heading "chapter 41, 42" for "chapter 42" and "43,
    or 44" for "or 43".
      Subsec. (d)(4). Pub. L. 94-455, Sec. 2107(g)(2)(C), inserted ",
    an investment credit carryback," after "net operating loss
    carryback".
      Subsec. (h). Pub. L. 94-455, Sec. 1906(a)(34), struck out "(or
    section 59 of the Internal Revenue Code of 1939)".
      Subsecs. (j), (k). Pub. L. 94-455, Sec. 2004(b), added subsec.
    (j) and redesignated former subsec. (j) as (k).
      1975 - Subsec. (a). Pub. L. 93-625, Sec. 7(a)(2)(A), substituted
    "an annual rate established under section 6621" for "the rate of 6
    percent per annum".
      Subsecs. (b) to (l). Pub. L. 93-625, Sec. 7(b)(1), struck out
    subsec. (b) relating to extensions of time for payment of estate
    tax, redesignated subsecs. (c) to (i) as (b) to (h), respectively,
    struck out subsec. (j) relating to extensions of time for payment
    of tax attributable to recoveries of foreign expropriation losses,
    and redesignated subsecs. (k) and (l) as (i) and (j), respectively.
      1974 - Subsec. (d). Pub. L. 93-406 inserted reference to chapter
    43 in heading, and substituted "certain excise" for "chapter 42" in
    text.
      1971 - Subsec. (e)(4). Pub. L. 92-178 added par. (4).
      1969 - Subsec. (d). Pub. L. 91-172, Sec. 101(j)(49), inserted
    reference to chapter 42 both in subsec. heading and in text.
      Subsec. (e)(1). Pub. L. 91-172, Sec. 512(e)(3)(A), (B),
    substituted "loss or capital loss carryback" for "loss carryback"
    in heading, and "net operating loss or net capital loss" for "net
    operating loss" wherever it appears in text.
      Subsec. (e)(2). Pub. L. 91-172, Sec. 512(e)(3)(C), substituted
    "loss carryback or a capital loss carryback" for "loss carryback".
      Subsecs. (k), (l). Pub. L. 91-53 added subsec. (k) and
    redesignated former subsec. (k) as (l).
      1967 - Subsec. (e)(2). Pub. L. 90-225 inserted ", or with respect
    to any portion of an investment credit carryback from a taxable
    year attributable to a net operating loss carryback from a
    subsequent taxable year, such increase shall not affect the
    computation of interest under this section for the period ending
    with the last day of such subsequent taxable year," after "the
    investment credit carryback arises".
      1966 - Subsecs. (j), (k). Pub. L. 89-384 added subsec. (j) and
    redesignated former subsec. (j) as (k).
      1964 - Subsec. (e). Pub. L. 88-571 added par. (3) and inserted
    "or adjustment for certain unused deductions" in heading.
      1962 - Subsec. (e). Pub. L. 87-834 designated existing provisions
    as par. (1) and added par. (2).
      1961 - Subsec. (c)(2). Pub. L. 87-61 substituted "6152(a) or
    6156(a)" for "6152(a)" in introductory provisions, and "6152(b) or
    6156(b), as the case may be" for "6152(b)" in subpar. (A).
      1958 - Subsec. (b). Pub. L. 85-866, Secs. 66(c), 206(e), inserted
    reference to section 6166, and substituted "if the time for payment
    of an amount of such tax is postponed or extended as provided by
    section 6163" for "if postponement of the payment of an amount of
    such tax is permitted by section 6163(a)".
      Subsecs. (g) to (j). Pub. L. 85-866, Secs. 83(a)(1), 84(a), added
    subsecs. (g) and (h) and redesignated former subsecs. (g) and (h)
    as (h) and (i), respectively.

                     EFFECTIVE DATE OF 2005 AMENDMENT                 
      Amendment by Pub. L. 109-135 effective as if included in the
    provisions of the Taxpayer Relief Act of 1997, Pub. L. 105-34, to
    which such amendment relates, see section 409(d) of Pub. L. 109-
    135, set out as a note under section 961 of this title.

                     EFFECTIVE DATE OF 1998 AMENDMENT                 
      Pub. L. 105-206, title III, Sec. 3301(c), July 22, 1998, 112
    Stat. 741, as amended by Pub. L. 105-277, div. J, title IV, Sec.
    4002(d), Oct. 21, 1998, 112 Stat. 2681-906, provided that:
      "(1) In general. - Except as provided under paragraph (2), the
    amendments made by this section [amending this section and section
    6621 of this title] shall apply to interest for periods beginning
    after the date of the enactment of this Act [July 22, 1998].
      "(2) Special rule. - Subject to any applicable statute of
    limitation not having expired with regard to either a tax
    underpayment or a tax overpayment, the amendments made by this
    section shall apply to interest for periods beginning before the
    date of the enactment of this Act if the taxpayer - 
        "(A) reasonably identifies and establishes periods of such tax
      overpayments and underpayments for which the zero rate applies;
      and
        "(B) not later than December 31, 1999, requests the Secretary
      of the Treasury to apply section 6621(d) of the Internal Revenue
      Code of 1986, as added by subsection (a), to such periods."

                     EFFECTIVE DATE OF 1997 AMENDMENT                 
      Amendment by section 501(e) of Pub. L. 105-34 applicable to
    estates of decedents dying, and gifts made, after Dec. 31, 1997,
    see section 501(f) of Pub. L. 105-34, set out as a note under
    section 2001 of this title.
      Amendment by section 503(a), (c)(2), (3) of Pub. L. 105-34
    applicable to estates of decedents dying after Dec. 31, 1997, with
    special rule in case of estate of any decedent dying before Jan. 1,
    1998, with respect to which there is an election under section 6166
    of this title, see section 503(d) of Pub. L. 105-34, set out as a
    note under section 163 of this title.
      Section 1055(c) of Pub. L. 105-34 provided that: "The amendments
    made by this section [amending this section and section 6611 of
    this title] shall apply to foreign tax credit carrybacks arising in
    taxable years beginning after the date of the enactment of this Act
    [Aug. 5, 1997]."
      Section 1242(b) of Pub. L. 105-34 provided that: "The amendment
    made by this section [amending this section] shall apply to
    adjustments with respect to partnership taxable years beginning
    after the date of the enactment of this Act [Aug. 5, 1997]."

                     EFFECTIVE DATE OF 1996 AMENDMENT                 
      Section 303(c) of Pub. L. 104-168 provided that: "The amendments
    made by this section [amending this section and section 6651 of
    this title] shall apply in the case of any notice and demand given
    after December 31, 1996."

                     EFFECTIVE DATE OF 1989 AMENDMENT                 
      Amendment by Pub. L. 101-239 applicable to returns the due date
    for which (determined without regard to extensions) is after Dec.
    31, 1989, see section 7721(d) of Pub. L. 101-239, set out as a note
    under section 461 of this title.

                     EFFECTIVE DATE OF 1988 AMENDMENT                 
      Amendment by section 1015(b)(2)(C) of Pub. L. 100-647 applicable
    to returns the due date for which (determined without regard to
    extensions) is after Dec. 31, 1988, see section 1015(b)(4) of Pub.
    L. 100-647, set out as a note under section 6013 of this title.
      Amendment by section 1018(u)(42) of Pub. L. 100-647 effective,
    except as otherwise provided, as if included in the provision of
    the Tax Reform Act of 1986, Pub. L. 99-514, to which such amendment
    relates, see section 1019(a) of Pub. L. 100-647, set out as a note
    under section 1 of this title.
      Amendment by section 6234(b)(1) of Pub. L. 100-647 applicable to
    agreements entered into after Nov. 10, 1988, see section 6234(c) of
    Pub. L. 100-647, set out as an Effective Date note under section
    6159 of this title.
      Amendment by section 7106(c)(5) of Pub. L. 100-647 applicable to
    remuneration paid after Dec. 31, 1988, see section 7106(d) of Pub.
    L. 100-647, set out as a note under section 3321 of this title.

                     EFFECTIVE DATE OF 1987 AMENDMENT                 
      Amendment by Pub. L. 100-203 applicable to taxable years
    beginning after Dec. 31, 1987, see section 10301(c) of Pub. L. 100-
    203, set out as a note under section 585 of this title.

                     EFFECTIVE DATE OF 1986 AMENDMENT                 
      Amendment by section 1404(c)(3) of Pub. L. 99-514 applicable to
    taxable years beginning after Dec. 31, 1986, see section 1404(d) of
    Pub. L. 99-514, set out as a note under section 643 of this title.
      Amendment by section 1511(c)(11) of Pub. L. 99-514 applicable for
    purposes of determining interest for periods after Dec. 31, 1986,
    see section 1511(d) of Pub. L. 99-514, set out as a note under
    section 47 of this title.
      Section 1512(b) of Pub. L. 99-514 provided that: "The amendments
    made by this section [amending this section] shall apply to returns
    the due date for which (determined without regard to extensions) is
    after December 31, 1985."
      Section 1564(b) of Pub. L. 99-514 provided that:
      "(1) Effective date. - The amendment made by subsection (a)
    [amending this section] shall apply to interest accruing after
    December 31, 1982.
      "(2) Statute of limitations. - If refund or credit of any amount
    resulting from the application of the amendment made by subsection
    (a) is prevented at any time before the close of the date which is
    1 year after the date of the enactment of this Act [Oct. 22, 1986]
    by the operation of any law or rule of law (including res
    judicata), refund or credit of such amount (to the extent
    attributable to the application of the amendment made by subsection
    (a)) may, nevertheless, be made or allowed if claim therefore [sic]
    is filed before the close of such 1-year period."

                     EFFECTIVE DATE OF 1984 AMENDMENT                 
      Section 158(b) of Pub. L. 98-369 provided that: "The amendment
    made by this section [amending this section] shall apply to
    interest accrued after the date of the enactment of this Act [July
    18, 1984], except with respect to additions to tax for which notice
    and demand is made before such date."
      Amendment by section 211(b)(26) of Pub. L. 98-369 applicable to
    taxable years beginning after Dec. 31, 1983, see section 215 of
    Pub. L. 98-369, set out as an Effective Date note under section 801
    of this title.
      Amendment by section 412(b)(7) of Pub. L. 98-369 applicable with
    respect to taxable years beginning after Dec. 31, 1984, see section
    414(a)(1) of Pub. L. 98-369, set out as a note under section 6654
    of this title.
      Amendment by section 714(n)(1) of Pub. L. 98-369 effective as if
    included in the provision of the Tax Equity and Fiscal
    Responsibility Act of 1982, Pub. L. 97-248, to which such amendment
    relates, see section 715 of Pub. L. 98-369, set out as a note under
    section 31 of this title.

                     EFFECTIVE DATE OF 1983 AMENDMENT                 
      Amendment by Pub. L. 98-76 applicable to remuneration paid after
    June 30, 1986, see section 231(d) of Pub. L. 98-76, set out as an
    Effective Date note under section 3321 of this title.

                     EFFECTIVE DATE OF 1982 AMENDMENT                 
      Amendment by section 344(b)(1) of Pub. L. 97-248 applicable to
    interest accruing after Dec. 31, 1982, see section 344(c) of Pub.
    L. 97-248, set out as an Effective Date note under section 6622 of
    this title.
      Amendment by section 346(c)(2) of Pub. L. 97-248 applicable to
    interest accruing after the 30th day after Sept. 3, 1982, see
    section 346(d)(2) of Pub. L. 97-248, set out as a note under
    section 6611 of this title.

                     EFFECTIVE DATE OF 1980 AMENDMENT                 
      Amendment by Pub. L. 96-223 applicable to periods after Feb. 29,
    1980, see section 101(i) of Pub. L. 96-223, set out as a note under
    section 6161 of this title.

                     EFFECTIVE DATE OF 1978 AMENDMENT                 
      Amendment by Pub. L. 95-628 applicable to carrybacks arising in
    taxable years beginning after Nov. 10, 1978, see section 8(d) of
    Pub. L. 95-628, set out as a note under section 6511 of this title.

                     EFFECTIVE DATE OF 1977 AMENDMENT                 
      Amendment by Pub. L. 95-30 applicable to taxable years beginning
    after Dec. 31, 1976, and to credit carrybacks from such years, see
    section 202(e) of Pub. L. 95-30, set out as an Effective Date note
    under section 51 of this title.

                     EFFECTIVE DATE OF 1976 AMENDMENTS                 
      Amendment by section 2004(b) of Pub. L. 94-455 applicable to
    estates of decedents dying after Dec. 31, 1976, see section 2004(g)
    of Pub. L. 94-455, set out as a note under section 6166 of this
    title.
      Amendment by Pub. L. 94-452 effective Oct. 1, 1977, see section
    3(e) of Pub. L. 94-452, set out as a note under section 6151 of
    this title.

                     EFFECTIVE DATE OF 1975 AMENDMENT                 
      Amendment by Pub. L. 93-625 effective July 1, 1975, and
    applicable to amounts outstanding on such date or arising
    thereafter, see section 7(e) of Pub. L. 93-625, set out as an
    Effective Date note under section 6621 of this title.

                     EFFECTIVE DATE OF 1974 AMENDMENT                 
      Amendment by Pub. L. 93-406 applicable, except as otherwise
    provided in section 1017(c) through (i) of Pub. L. 93-406, for plan
    years beginning after Sept. 2, 1974, but, in the case of plans in
    existence on Jan. 1, 1974, amendment by Pub. L. 93-406 applicable
    for plan years beginning after Dec. 31, 1975, see section 1017 of
    Pub. L. 93-406, set out as an Effective Date; Transitional Rules
    note under section 410 of this title.

                     EFFECTIVE DATE OF 1971 AMENDMENT                 
      Amendment by Pub. L. 92-178 applicable to taxable years beginning
    after Dec. 31, 1971, see section 601(f) of Pub. L. 92-178, set out
    as a note under section 381 of this title.

                     EFFECTIVE DATE OF 1969 AMENDMENT                 
      Amendment by section 101(j)(49) of Pub. L. 91-172 effective Jan.
    1, 1970, see section 101(k)(1) of Pub. L. 91-172, set out as an
    Effective Date note under section 4940 of this title.
      Amendment by section 512(e)(3) of Pub. L. 91-172 applicable with
    respect to net capital losses sustained in taxable years beginning
    after Dec. 31, 1969, see section 512(g) of Pub. L. 91-172, set out
    as an Effective Date of 1969 Amendment note under section 1212 of
    this title. Amendment by Pub. L. 91-53 applicable with respect to
    calendar years beginning after Dec. 31, 1969, see section 4(a) of
    Pub. L. 91-53, set out as an Effective Date note under section 6157
    of this title.

                     EFFECTIVE DATE OF 1967 AMENDMENT                 
      Amendment by Pub. L. 90-225 applicable with respect to investment
    credit carrybacks attributable to net operating loss carrybacks
    from taxable years ending after July 31, 1967, see section 2(g) of
    Pub. L. 90-225, set out as a note under section 46 of this title.

                     EFFECTIVE DATE OF 1966 AMENDMENT                 
      Amendment by Pub. L. 89-384 applicable with respect to amounts
    received after December 31, 1964, in respect of foreign
    expropriation losses (as defined in section 1351(b) of this title)
    sustained after December 31, 1958, see section 2 of Pub. L. 89-384,
    set out as an Effective Date note under section 1351 of this title.

                     EFFECTIVE DATE OF 1964 AMENDMENT                 
      Amendment by Pub. L. 88-571 effective, with respect to amounts
    added to policyholders surplus accounts, for taxable years
    beginning after Dec. 31, 1958, see section 3(f) of Pub. L. 88-571,
    set out as a note under section 815 of this title.

                     EFFECTIVE DATE OF 1962 AMENDMENT                 
      Amendment by Pub. L. 87-834 applicable with respect to taxable
    years ending after Dec. 31, 1961, see section 2(h) of Pub. L. 87-
    834, set out as an Effective Date note under section 46 of this
    title.

                     EFFECTIVE DATE OF 1961 AMENDMENT                 
      Amendment by Pub. L. 87-61 effective July 1, 1961, see section
    208 of Pub. L. 87-61, set out as a note under section 4041 of this
    title.

                     EFFECTIVE DATE OF 1958 AMENDMENT                 
      Amendment by sections 66(c) and 84(a) of Pub. L. 85-866 effective
    Aug. 17, 1954, see section 1(c)(2) of Pub. L. 85-866, set out as a
    note under section 165 of this title.
      Section 83(d) of Pub. L. 85-866 provided that: "The amendments
    made by subsections (a) [amending this section and section 3794 of
    I.R.C. 1939], (b) [amending section 6611 of this title and section
    3771 of I.R.C. 1939], and (c) [amending section 6611 of this title]
    shall apply only in respect of overpayments credited after December
    31, 1957."
      For effective date of amendment by section 206(e) of Pub. L. 85-
    866, see section 206(f) of Pub. L. 85-866, set out as a note under
    section 6161 of this title.

                             SAVINGS PROVISION                         
      For provisions that nothing in amendment by Pub. L. 101-508 be
    construed to affect treatment of certain transactions occurring,
    property acquired, or items of income, loss, deduction, or credit
    taken into account prior to Nov. 5, 1990, for purposes of
    determining liability for tax for periods ending after Nov. 5,
    1990, see section 11821(b) of Pub. L. 101-508, set out as a note
    under section 45K of this title.

                 ADMINISTRATION OF PENALTIES AND INTEREST             
      Pub. L. 105-206, title III, Sec. 3801, July 22, 1998, 112 Stat.
    782, provided that: "The Joint Committee on Taxation and the
    Secretary of the Treasury shall each conduct a separate study - 
        "(1) reviewing the administration and implementation by the
      Internal Revenue Service of the interest and penalty provisions
      of the Internal Revenue Code of 1986 (including the penalty
      reform provisions of the Omnibus Budget Reconciliation Act of
      1989 [Pub. L. 101-239, see Tables for classification]); and
        "(2) making any legislative and administrative recommendations
      the Committee or the Secretary deems appropriate to simplify
      penalty or interest administration and reduce taxpayer burden.
    Such studies shall be submitted to the Committee on Ways and Means
    of the House of Representatives and the Committee on Finance of the
    Senate not later than 1 year after the date of the enactment of
    this Act [July 22, 1998]."

     INTEREST NOT PAYABLE ON UNDERPAYMENTS CREATED OR INCREASED BY TAX
                            REFORM ACT OF 1976
      Section 305 of Pub. L. 95-30, as amended by Pub. L. 99-514, Sec.
    2, Oct. 22, 1986, 100 Stat. 2095, provided that: "No interest shall
    be payable for any period before April 16, 1977 (March 16, 1977, in
    the case of a corporation), on any underpayment of a tax imposed by
    the Internal Revenue Code of 1986 [formerly I.R.C. 1954], to the
    extent that such underpayment was created or increased by any
    provision of the Tax Reform Act of 1976 [Pub. L. 94-455]."

                         INTEREST ON UNDERPAYMENT                     
      Section 946(a) of Pub. L. 91-172 provided that in the case of any
    taxable year ending before Dec. 30, 1969, no interest on
    underpayment of taxes, to the extent that such underpayment was
    attributable to the amendments made by Pub. L. 91-172, was not to
    be assessed or collected for any period before the 90th day after
    Dec. 30, 1969.

     INTEREST ATTRIBUTABLE TO NET OPERATING LOSS CARRYBACK FOR CERTAIN
                       TAXABLE YEARS ENDING IN 1954
      Section 83(e) of Pub. L. 85-866 provided that if by reason of the
    enactment of section 172(b)(1)(A) of this title, a deficiency
    resulted for the first taxable year preceding a taxable year ending
    after Dec. 31, 1953 but before Aug. 17, 1954 and an overpayment
    resulted in the second preceding taxable year, then no interest was
    payable for any portion of such deficiency for any period during
    which there existed a corresponding overpayment to which interest
    was not payable.

-FOOTNOTE-
    (!1) See References in Text note below.


-End-



-CITE-
    26 USC Sec. 6602                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter A - Interest on Underpayments

-HEAD-
    Sec. 6602. Interest on erroneous refund recoverable by suit

-STATUTE-
      Any portion of an internal revenue tax (or any interest,
    assessable penalty, additional amount, or addition to tax) which
    has been erroneously refunded, and which is recoverable by suit
    pursuant to section 7405, shall bear interest at the underpayment
    rate established under section 6621 from the date of the payment of
    the refund.

-SOURCE-
    (Aug. 16, 1954, ch. 736, 68A Stat. 818; Pub. L. 93-625, Sec.
    7(a)(2)(B), Jan. 3, 1975, 88 Stat. 2115; Pub. L. 99-514, title XV,
    Sec. 1511(c)(12), Oct. 22, 1986, 100 Stat. 2745.)


-MISC1-
                                AMENDMENTS                            
      1986 - Pub. L. 99-514 substituted "the underpayment rate
    established under section 6621" for "an annual rate established
    under section 6621".
      1975 - Pub. L. 93-625 substituted "an annual rate established
    under section 6621" for "the rate of 6 percent per annum".

                     EFFECTIVE DATE OF 1986 AMENDMENT                 
      Amendment by Pub. L. 99-514 applicable for purposes of
    determining interest for periods after Dec. 31, 1986, see section
    1511(d) of Pub. L. 99-514, set out as a note under section 47 of
    this title.

                     EFFECTIVE DATE OF 1975 AMENDMENT                 
      Amendment by Pub. L. 93-625 effective July 1, 1975, and
    applicable to amounts outstanding on such date or arising
    thereafter, see section 7(e) of Pub. L. 93-625, set out as an
    Effective Date note under section 6621 of this title.

-End-



-CITE-
    26 USC Sec. 6603                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter A - Interest on Underpayments

-HEAD-
    Sec. 6603. Deposits made to suspend running of interest on
      potential underpayments, etc.

-STATUTE-
    (a) Authority to make deposits other than as payment of tax
      A taxpayer may make a cash deposit with the Secretary which may
    be used by the Secretary to pay any tax imposed under subtitle A or
    B or chapter 41, 42, 43, or 44 which has not been assessed at the
    time of the deposit. Such a deposit shall be made in such manner as
    the Secretary shall prescribe.
    (b) No interest imposed
      To the extent that such deposit is used by the Secretary to pay
    tax, for purposes of section 6601 (relating to interest on
    underpayments), the tax shall be treated as paid when the deposit
    is made.
    (c) Return of deposit
      Except in a case where the Secretary determines that collection
    of tax is in jeopardy, the Secretary shall return to the taxpayer
    any amount of the deposit (to the extent not used for a payment of
    tax) which the taxpayer requests in writing.
    (d) Payment of interest
      (1) In general
        For purposes of section 6611 (relating to interest on
      overpayments), except as provided in paragraph (4), a deposit
      which is returned to a taxpayer shall be treated as a payment of
      tax for any period to the extent (and only to the extent)
      attributable to a disputable tax for such period. Under
      regulations prescribed by the Secretary, rules similar to the
      rules of section 6611(b)(2) shall apply.
      (2) Disputable tax
        (A) In general
          For purposes of this section, the term "disputable tax" means
        the amount of tax specified at the time of the deposit as the
        taxpayer's reasonable estimate of the maximum amount of any tax
        attributable to disputable items.
        (B) Safe harbor based on 30-day letter
          In the case of a taxpayer who has been issued a 30-day
        letter, the maximum amount of tax under subparagraph (A) shall
        not be less than the amount of the proposed deficiency
        specified in such letter.
      (3) Other definitions
        For purposes of paragraph (2) - 
        (A) Disputable item
          The term "disputable item" means any item of income, gain,
        loss, deduction, or credit if the taxpayer - 
            (i) has a reasonable basis for its treatment of such item,
          and
            (ii) reasonably believes that the Secretary also has a
          reasonable basis for disallowing the taxpayer's treatment of
          such item.
        (B) 30-day letter
          The term "30-day letter" means the first letter of proposed
        deficiency which allows the taxpayer an opportunity for
        administrative review in the Internal Revenue Service Office of
        Appeals.
      (4) Rate of interest
        The rate of interest under this subsection shall be the Federal
      short-term rate determined under section 6621(b), compounded
      daily.
    (e) Use of deposits
      (1) Payment of tax
        Except as otherwise provided by the taxpayer, deposits shall be
      treated as used for the payment of tax in the order deposited.
      (2) Returns of deposits
        Deposits shall be treated as returned to the taxpayer on a last-
      in, first-out basis.

-SOURCE-
    (Added Pub. L. 108-357, title VIII, Sec. 842(a), Oct. 22, 2004, 118
    Stat. 1598.)


-MISC1-
                              EFFECTIVE DATE                          
      Pub. L. 108-357, title VIII, Sec. 842(c), Oct. 22, 2004, 118
    Stat. 1599, provided that:
      "(1) In general. - The amendments made by this section [enacting
    this section] shall apply to deposits made after the date of the
    enactment of this Act [Oct. 22, 2004].
      "(2) Coordination with deposits made under revenue procedure 84-
    58. - In the case of an amount held by the Secretary of the
    Treasury or his delegate on the date of the enactment of this Act
    as a deposit in the nature of a cash bond deposit pursuant to
    Revenue Procedure 84-58, the date that the taxpayer identifies such
    amount as a deposit made pursuant to section 6603 of the Internal
    Revenue Code (as added by this Act) shall be treated as the date
    such amount is deposited for purposes of such section 6603."

-End-


-CITE-
    26 USC Subchapter B - Interest on Overpayments              01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter B - Interest on Overpayments

-HEAD-
                  SUBCHAPTER B - INTEREST ON OVERPAYMENTS              

-MISC1-
    Sec.                                                     
    6611.       Interest on overpayments.                             
    6612.       Cross references.                                     

-End-



-CITE-
    26 USC Sec. 6611                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter B - Interest on Overpayments

-HEAD-
    Sec. 6611. Interest on overpayments

-STATUTE-
    (a) Rate
      Interest shall be allowed and paid upon any overpayment in
    respect of any internal revenue tax at the overpayment rate
    established under section 6621.
    (b) Period
      Such interest shall be allowed and paid as follows:
      (1) Credits
        In the case of a credit, from the date of the overpayment to
      the due date of the amount against which the credit is taken.
      (2) Refunds
        In the case of a refund, from the date of the overpayment to a
      date (to be determined by the Secretary) preceding the date of
      the refund check by not more than 30 days, whether or not such
      refund check is accepted by the taxpayer after tender of such
      check to the taxpayer. The acceptance of such check shall be
      without prejudice to any right of the taxpayer to claim any
      additional overpayment and interest thereon.
      (3) Late returns
        Notwithstanding paragraph (1) or (2) in the case of a return of
      tax which is filed after the last date prescribed for filing such
      return (determined with regard to extensions), no interest shall
      be allowed or paid for any day before the date on which the
      return is filed.
    [(c) Repealed. Pub. L. 85-866, title I, Sec. 83(c), Sept. 2, 1958,
      72 Stat. 1664]
    (d) Advance payment of tax, payment of estimated tax, and credit
      for income tax withholding
      The provisions of section 6513 (except the provisions of
    subsection (c) thereof, applicable in determining the date of
    payment of tax for purposes of determining the period of limitation
    on credit or refund, shall be applicable in determining the date of
    payment for purposes of subsection (a).
    (e) Disallowance of interest on certain overpayments
      (1) Refunds within 45 days after return is filed
        If any overpayment of tax imposed by this title is refunded
      within 45 days after the last day prescribed for filing the
      return of such tax (determined without regard to any extension of
      time for filing the return) or, in the case of a return filed
      after such last date, is refunded within 45 days after the date
      the return is filed, no interest shall be allowed under
      subsection (a) on such overpayment.
      (2) Refunds after claim for credit or refund
        If - 
          (A) the taxpayer files a claim for a credit or refund for any
        overpayment of tax imposed by this title, and
          (B) such overpayment is refunded within 45 days after such
        claim is filed,

      no interest shall be allowed on such overpayment from the date
      the claim is filed until the day the refund is made.
      (3) IRS initiated adjustments
        If an adjustment initiated by the Secretary, results in a
      refund or credit of an overpayment, interest on such overpayment
      shall be computed by subtracting 45 days from the number of days
      interest would otherwise be allowed with respect to such
      overpayment.
    (f) Refund of income tax caused by carryback or adjustment for
      certain unused deductions
      (1) Net operating loss or capital loss carryback
        For purposes of subsection (a), if any overpayment of tax
      imposed by subtitle A results from a carryback of a net operating
      loss or net capital loss, such overpayment shall be deemed not to
      have been made prior to the filing date for the taxable year in
      which such net operating loss or net capital loss arises.
      (2) Foreign tax credit carrybacks
        For purposes of subsection (a), if any overpayment of tax
      imposed by subtitle A results from a carryback of tax paid or
      accrued to foreign countries or possessions of the United States,
      such overpayment shall be deemed not to have been made before the
      filing date for the taxable year in which such taxes were in fact
      paid or accrued, or, with respect to any portion of such credit
      carryback from a taxable year attributable to a net operating
      loss carryback or a capital loss carryback from a subsequent
      taxable year, such overpayment shall be deemed not to have been
      made before the filing date for such subsequent taxable year.
      (3) Certain credit carrybacks
        (A) In general
          For purposes of subsection (a), if any overpayment of tax
        imposed by subtitle A results from a credit carryback, such
        overpayment shall be deemed not to have been made before the
        filing date for the taxable year in which such credit carryback
        arises, or, with respect to any portion of a credit carryback
        from a taxable year attributable to a net operating loss
        carryback, capital loss carryback, or other credit carryback
        from a subsequent taxable year, such overpayment shall be
        deemed not to have been made before the filing date for such
        subsequent taxable year.
        (B) Credit carryback defined
          For purposes of this paragraph, the term "credit carryback"
        has the meaning given such term by section 6511(d)(4)(C).
      (4) Special rules for paragraphs (1), (2), and (3)
        (A) Filing date
          For purposes of this subsection, the term "filing date" means
        the last date prescribed for filing the return of tax imposed
        by subtitle A for the taxable year (determined without regard
        to extensions).
        (B) Coordination with subsection (e)
          (i) In general
            For purposes of subsection (e) - 
              (I) any overpayment described in paragraph (1), (2), or
            (3) shall be treated as an overpayment for the loss year,
              (II) such subsection shall be applied with respect to
            such overpayment by treating the return for the loss year
            as not filed before claim for such overpayment is filed.
          (ii) Loss year
            For purposes of this subparagraph, the term "loss year"
          means - 
              (I) in the case of a carryback of a net operating loss or
            net capital loss, the taxable year in which such loss
            arises,
              (II) in the case of a carryback of taxes paid or accrued
            to foreign countries or possessions of the United States,
            the taxable year in which such taxes were in fact paid or
            accrued (or, with respect to any portion of such carryback
            from a taxable year attributable to a net operating loss
            carryback or a capital loss carryback from a subsequent
            taxable year, such subsequent taxable year), and
              (III) in the case of a credit carryback (as defined in
            paragraph (3)(B)), the taxable year in which such credit
            carryback arises (or, with respect to any portion of a
            credit carryback from a taxable year attributable to a net
            operating loss carryback, a capital loss carryback, or
            other credit carryback from a subsequent taxable year, such
            subsequent taxable year).
        (C) Application of subparagraph (B) where section 6411(a) claim
          filed
          For purposes of subparagraph (B)(i)(II), if a taxpayer - 
            (i) files a claim for refund of any overpayment described
          in paragraph (1), (2), or (3) with respect to the taxable
          year to which a loss or credit is carried back, and
            (ii) subsequently files an application under section
          6411(a) with respect to such overpayment,

        then the claim for overpayment shall be treated as having been
        filed on the date the application under section 6411(a) was
        filed.
    (g) No interest until return in processible form
        (1) For purposes of subsections (b)(3) and (e), a return shall
      not be treated as filed until it is filed in processible form.
        (2) For purposes of paragraph (1), a return is in a processible
      form if - 
          (A) such return is filed on a permitted form, and
          (B) such return contains - 
            (i) the taxpayer's name, address, and identifying number
          and the required signature, and
            (ii) sufficient required information (whether on the return
          or on required attachments) to permit the mathematical
          verification of tax liability shown on the return.
    (h) Prohibition of administrative review
          For prohibition of administrative review, see section 6406.

-SOURCE-
    (Aug. 16, 1954, ch. 736, 68A Stat. 819; Pub. L. 85-866, title I,
    Secs. 42(b), 83(b), (c), Sept. 2, 1958, 72 Stat. 1640, 1664; Pub.
    L. 87-834, Sec. 2(e)(4), Oct. 16, 1962, 76 Stat. 972; Pub. L. 88-
    571, Sec. 3(e), Sept. 2, 1964, 78 Stat. 858; Pub. L. 89-721, Sec.
    1(a), Nov. 2, 1966, 80 Stat. 1150; Pub. L. 90-225, Sec. 2(f), Dec.
    27, 1967, 81 Stat. 732; Pub. L. 91-172, title V, Sec. 512(e)(4),
    Dec. 30, 1969, 83 Stat. 641; Pub. L. 92-178, title VI, Sec.
    601(d)(4), Dec. 10, 1971, 85 Stat. 559; Pub. L. 93-17, Sec.
    3(i)(2), Apr. 10, 1973, 87 Stat. 19; Pub. L. 93-625, Sec.
    7(a)(2)(C), Jan. 3, 1975, 88 Stat. 2115; Pub. L. 94-455, title XIX,
    Sec. 1904(b)(10)(A)(iv), 1906(b)(13)(A), title XXI, Sec.
    2107(g)(2)(D), Oct. 4, 1976, 90 Stat. 1817, 1834, 1904; Pub. L. 95-
    30, title II, Sec. 202(d)(4)(D), May 23, 1977, 91 Stat. 150; Pub.
    L. 95-628, Sec. 8(c)(3), Nov. 10, 1978, 92 Stat. 3632; Pub. L. 96-
    223, title I, Sec. 101(h), Apr. 2, 1980, 94 Stat. 254; Pub. L. 97-
    248, title III, Sec. 346(a)-(c)(1), Sept. 3, 1982, 96 Stat. 636,
    637; Pub. L. 98-369, div. A, title II, Sec. 211(b)(27), title VII,
    Sec. 714(n)(2)(A), July 18, 1984, 98 Stat. 757, 963; Pub. L. 99-
    514, title XV, Sec. 1511(c)(13), Oct. 22, 1986, 100 Stat. 2745;
    Pub. L. 100-418, title I, Sec. 1941(b)(2)(L), Aug. 23, 1988, 102
    Stat. 1323; Pub. L. 103-66, title XIII, Sec. 13271(a), Aug. 10,
    1993, 107 Stat. 541; Pub. L. 105-34, title X, Sec. 1055(b), Aug. 5,
    1997, 111 Stat. 944; Pub. L. 105-206, title VI, Sec. 6010(l), July
    22, 1998, 112 Stat. 816; Pub. L. 106-554, Sec. 1(a)(7) [title III,
    Sec. 319(20)], Dec. 21, 2000, 114 Stat. 2763, 2763A-647.)


-MISC1-
                                AMENDMENTS                            
      2000 - Subsec. (g)(1). Pub. L. 106-554 struck out comma after
    "(b)(3)".
      1998 - Subsec. (g)(1). Pub. L. 105-206 substituted "and (e)" for
    "(e), and (h)".
      1997 - Subsec. (f)(2), (3). Pub. L. 105-34, Sec. 1055(b)(1),
    added par. (2) and redesignated former par. (2) as (3). Former par.
    (3) redesignated (4).
      Subsec. (f)(4). Pub. L. 105-34, Sec. 1055(b)(1), (2)(A)(i),
    redesignated par. (3) as (4) and substituted "paragraphs (1), (2),
    and (3)" for "paragraphs (1) and (2)" in heading.
      Subsec. (f)(4)(B)(i)(I). Pub. L. 105-34, Sec. 1055(b)(2)(A),
    substituted "paragraph (1), (2), or (3)" for "paragraph (1) or
    (2)".
      Subsec. (f)(4)(B)(ii)(II). Pub. L. 105-34, Sec. 1055(b)(2)(B),
    added subcl. (II). Former subcl. (II) redesignated (III).
      Subsec. (f)(4)(B)(ii)(III). Pub. L. 105-34, Sec. 1055(b)(2)(B),
    (C), redesignated subcl. (II) as (III) and inserted "(as defined in
    paragraph (3)(B))" after "case of a credit carryback".
      Subsec. (f)(4)(C)(i). Pub. L. 105-34, Sec. 1055(b)(2)(A),
    substituted "paragraph (1), (2), or (3)" for "paragraph (1) or
    (2)".
      Subsecs. (g) to (i). Pub. L. 105-34, Sec. 1055(b)(2)(D),
    redesignated subsecs. (h) and (i) as (g) and (h), respectively, and
    struck out former subsec. (g) which read as follows:
      "(g) Refund of Income Tax Caused by Carryback of Foreign Taxes. -
    For purposes of subsection (a), if any overpayment of tax results
    from a carryback of tax paid or accrued to foreign countries or
    possessions of the United States, such overpayment shall be deemed
    not to have been paid or accrued prior to the filing date (as
    defined in subsection (f)(3)) for the taxable year under this
    subtitle in which such taxes were in fact paid or accrued."
      1993 - Subsec. (e). Pub. L. 103-66 amended heading and text of
    subsec. (e) generally. Prior to amendment, text read as follows:
    "If any overpayment of tax imposed by subtitle A is refunded within
    45 days after the last date prescribed for filing the return of
    such tax (determined without regard to any extension of time for
    filing the return) or, in case the return is filed after such last
    date, is refunded within 45 days after the date the return is
    filed, no interest shall be allowed under subsection (a) on such
    overpayment."
      1988 - Subsecs. (h) to (j). Pub. L. 100-418 redesignated subsecs.
    (i) and (j) as (h) and (i), respectively, and struck out former
    subsec. (h) which related to special rule for windfall profit tax.
      1986 - Subsec. (a). Pub. L. 99-514 substituted "the overpayment
    rate established under section 6621" for "an annual rate
    established under section 6621".
      1984 - Subsec. (f)(3)(C). Pub. L. 98-369, Sec. 714(n)(2)(A),
    added subpar. (C).
      Subsec. (f)(4). Pub. L. 98-369, Sec. 211(b)(27), struck out par.
    (4) which provided that for purposes of subsection (a), if any
    overpayment of tax imposed by subtitle A arose by operation of
    section 815(d)(5) (relating to reduction of policyholders surplus
    account of life insurance companies for certain unused deductions),
    such overpayment would be deemed not to have been made prior to the
    close of the last taxable year to which the loss described in
    section 815(d)(5)(A) was carried under section 812(b)(2).
      1982 - Subsec. (b)(3). Pub. L. 97-248, Sec. 346(a), added par.
    (3).
      Subsec. (f)(1). Pub. L. 97-248, Sec. 346(c)(1)(A), substituted
    "the filing date for the taxable year" for "the close of the
    taxable year".
      Subsec. (f)(2)(A). Pub. L. 97-248, Sec. 346(c)(1)(B), substituted
    "the filing date for" for "the close of" wherever appearing.
      Subsec. (f)(3), (4). Pub. L. 97-248, Sec. 346(c)(1)(C), added
    par. (3) and redesignated former par. (3) as (4).
      Subsec. (g). Pub. L. 97-248, Sec. 346(c)(1)(D), substituted "the
    filing date (as defined in subsection (f)(3)) for the taxable year"
    for "the close of the taxable year".
      Subsecs. (i), (j). Pub. L. 97-248, Sec. 346(b), added subsec. (i)
    and redesignated former subsec. (i) as (j).
      1980 - Subsecs. (h), (i). Pub. L. 96-223 added subsec. (h) and
    redesignated former subsec. (h) as (i).
      1978 - Subsec. (f)(2). Pub. L. 95-628, Sec. 8(c)(3)(A),
    substituted in heading "Certain credit carrybacks" for "Investment
    credit carryback", designated existing provision as subpar. (A),
    and in subpar. (A) as so designated inserted heading "In general"
    and extended the application of provision to credit carrybacks,
    previously limited to investment credit carrybacks, included other
    credit carrybacks, and added subpar. (B).
      Subsec. (f)(4), (5). Pub. L. 95-628, Sec. 8(c)(3)(B), struck out
    pars. (4) and (5) which provided for work incentive program credit
    carrybacks and new employee credit carrybacks, respectively.
      1977 - Subsec. (f)(5). Pub. L. 95-30 added par. (5).
      1976 - Subsec. (b). Pub. L. 94-455, Sec. 1906(b)(13)(A), struck
    out "or his delegate" after "Secretary".
      Subsec. (f)(4). Pub. L. 94-455, Sec. 2107(g)(2)(D), inserted ",
    an investment credit carryback," after "net operating loss
    carryback".
      Subsecs. (h), (i). Pub. L. 94-455, Sec. 1904(b)(10)(A)(iv),
    redesignated subsec. (i) as (h). Former subsec. (h), which related
    to a refund within 45 days after filing claim for refund of
    interest equalization tax paid on securities sold to foreigners,
    was struck out.
      1975 - Subsec. (a). Pub. L. 93-625 substituted "an annual rate
    established under section 6621" for "the rate of 6 percent per
    annum".
      1973 - Subsecs. (h), (i). Pub. L. 93-17 added subsec. (h) and
    redesignated former subsec. (h) as (i).
      1971 - Subsec. (f)(4). Pub. L. 92-178 added par. (4).
      1969 - Subsec. (f)(1). Pub. L. 91-172, Sec. 512(e)(4)(A), (B),
    substituted "loss or capital loss carryback" for "loss carryback"
    in heading, and "net operating loss or net capital loss" for "net
    operating loss" wherever appearing in text.
      Subsec. (f)(2). Pub. L. 91-172, Sec. 512(e)(4)(C), substituted
    "loss carryback or a capital loss carryback" for "loss carryback".
      1967 - Subsec. (f)(2). Pub. L. 90-225 inserted ", or, with
    respect to any portion of an investment credit carryback from a
    taxable year attributable to a net operating loss carryback from a
    subsequent taxable year, such overpayment shall be deemed not to
    have been made prior to the close of such subsequent taxable year"
    after "such investment credit carryback arises".
      1966 - Subsec. (e). Pub. L. 89-721 inserted "or, in case the
    return is filed after such last date, is refunded within 45 days
    after the date the return is filed" after "(determined without
    regard to any extension of time for filing the return)" and changed
    heading to reflect amendment.
      1964 - Subsec. (f). Pub. L. 88-571 added par. (3) and inserted
    "or adjustment for certain unused deductions" in heading.
      1962 - Subsec. (f). Pub. L. 87-834 designated existing provisions
    as par. (1) and added par. (2).
      1958 - Subsec. (b)(1). Pub. L. 85-866, Sec. 83(b), struck out ",
    but if the amount against which the credit is taken is an
    additional assessment, then to the date of the assessment of that
    amount" after "taken".
      Subsec. (c). Pub. L. 85-866, Sec. 83(c), repealed subsec. (c)
    which defined "additional assessment".
      Subsecs. (g), (h). Pub. L. 85-866, Sec. 42(b), added subsec. (g)
    and redesignated former subsec. (g) as (h).

                     EFFECTIVE DATE OF 1998 AMENDMENT                 
      Amendment by Pub. L. 105-206 effective, except as otherwise
    provided, as if included in the provisions of the Taxpayer Relief
    Act of 1997, Pub. L. 105-34, to which such amendment relates, see
    section 6024 of Pub. L. 105-206, set out as a note under section 1
    of this title.

                     EFFECTIVE DATE OF 1997 AMENDMENT                 
      Amendment by Pub. L. 105-34 applicable to foreign tax credit
    carrybacks arising in taxable years beginning after Aug. 5, 1997,
    see section 1055(c) of Pub. L. 105-34, set out as a note under
    section 6601 of this title.

                     EFFECTIVE DATE OF 1993 AMENDMENT                 
      Section 13271(b) of Pub. L. 103-66 provided that:
      "(1) Paragraph (1) of section 6611(e) of the Internal Revenue
    Code of 1986 (as amended by subsection (a)) shall apply in the case
    of returns the due date for which (determined without regard to
    extensions) is on or after January 1, 1994.
      "(2) Paragraph (2) of section 6611(e) of such Code (as so
    amended) shall apply in the case of claims for credit or refund of
    any overpayment filed on or after January 1, 1995, regardless of
    the taxable period to which such refund relates.
      "(3) Paragraph (3) of section 6611(e) of such Code (as so
    amended) shall apply in the case of any refund paid on or after
    January 1, 1995, regardless of the taxable period to which such
    refund relates."

                     EFFECTIVE DATE OF 1988 AMENDMENT                 
      Amendment by Pub. L. 100-418 applicable to crude oil removed from
    the premises on or after Aug. 23, 1988, see section 1941(c) of Pub.
    L. 100-418, set out as a note under section 164 of this title.

                     EFFECTIVE DATE OF 1986 AMENDMENT                 
      Amendment by Pub. L. 99-514 applicable for purposes of
    determining interest for periods after Dec. 31, 1986, see section
    1511(d) of Pub. L. 99-514, set out as a note under section 47 of
    this title.

                     EFFECTIVE DATE OF 1984 AMENDMENTS                 
      Amendment by section 211(b)(27) of Pub. L. 98-369 applicable to
    taxable years beginning after Dec. 31, 1983, see section 215 of
    Pub. L. 98-369, set out as an Effective Date note under section 801
    of this title.
      Amendment by section 714(n)(2)(A) of Pub. L. 98-369 effective as
    if included in the provision of the Tax Equity and Fiscal
    Responsibility Act of 1982, Pub. L. 97-248, to which such amendment
    relates, see section 715 of Pub. L. 98-369, set out as a note under
    section 31 of this title.
      Section 1875(d)(3) of Pub. L. 99-514 provided that:
    "Notwithstanding section 715 of the Tax Reform Act of 1984 [Pub. L.
    98-369], the amendments made by section 714(n)(2) of such Act
    [amending this section and section 6411 of this title] shall apply
    only to applications filed after July 18, 1984."

                     EFFECTIVE DATE OF 1982 AMENDMENT                 
      Section 346(d) of Pub. L. 97-248 provided that:
      "(1) In general. - The amendments made by subsections (a) and (b)
    [amending this section] shall apply to returns filed after the 30th
    day after the date of the enactment of this Act [Sept. 3, 1982].
      "(2) Subsection (c). - The amendments made by subsection (c)
    [amending this section and section 6601 of this title] shall apply
    to interest accruing after the 30th day after the date of the
    enactment of this Act [Sept. 3, 1982]."

                     EFFECTIVE DATE OF 1980 AMENDMENT                 
      Amendment by Pub. L. 96-223 applicable to periods after Feb. 29,
    1980, see section 101(i) of Pub. L. 96-223, set out as a note under
    section 6161 of this title.

                     EFFECTIVE DATE OF 1978 AMENDMENT                 
      Amendment by Pub. L. 95-628 applicable to carrybacks arising in
    taxable years beginning after Nov. 10, 1978, see section 8(d) of
    Pub. L. 95-628, set out as a note under section 6511 of this title.

                     EFFECTIVE DATE OF 1977 AMENDMENT                 
      Amendment by Pub. L. 95-30 applicable to taxable years beginning
    after Dec. 31, 1976, and to credit carrybacks from such years, see
    section 202(e) of Pub. L. 95-30, set out as an Effective Date note
    under section 51 of this title.

                     EFFECTIVE DATE OF 1975 AMENDMENT                 
      Amendment by Pub. L. 93-625 effective July 1, 1975, and
    applicable to amounts outstanding on such date or arising
    thereafter, see section 7(e) of Pub. L. 93-625, set out as an
    Effective Date note under section 6621 of this title.

                     EFFECTIVE DATE OF 1971 AMENDMENT                 
      Amendment by Pub. L. 92-178 applicable to taxable years beginning
    after Dec. 31, 1971, see section 601(f) of Pub. L. 92-178, set out
    as a note under section 381 of this title.

                     EFFECTIVE DATE OF 1969 AMENDMENT                 
      Amendment by Pub. L. 91-172 applicable with respect to net
    capital losses sustained in taxable years beginning after Dec. 31,
    1969, see section 512(g) of Pub. L. 91-172, set out as a note under
    section 1212 of this title.

                     EFFECTIVE DATE OF 1967 AMENDMENT                 
      Amendment by Pub. L. 90-225 applicable with respect to investment
    credit carrybacks attributable to net operating loss carrybacks
    from taxable years ending after July 31, 1967, see section 2(g) of
    Pub. L. 90-225, set out as a note under section 46 of this title.

                     EFFECTIVE DATE OF 1966 AMENDMENT                 
      Section 1(b) of Pub. L. 89-721 provided that: "The amendment made
    by subsection (a) [amending this section] shall apply with respect
    to refunds made more than 45 days after the date of the enactment
    of this Act [Nov. 2, 1966]."

                     EFFECTIVE DATE OF 1964 AMENDMENT                 
      Amendment by Pub. L. 88-571 effective, with respect to amounts
    added to policyholders surplus accounts, for taxable years
    beginning after Dec. 31, 1958, see section 3(f) of Pub. L. 88-571,
    set out as a note under section 815 of this title.

                     EFFECTIVE DATE OF 1962 AMENDMENT                 
      Amendment by Pub. L. 87-834 applicable with respect to taxable
    years ending after Dec. 31, 1961, see section 2(h) of Pub. L. 87-
    834, set out as an Effective Date note under section 46 of this
    title.

                     EFFECTIVE DATE OF 1958 AMENDMENT                 
      Amendment by section 42(b) of Pub. L. 85-866 applicable only with
    respect to taxable years beginning after Dec. 31, 1957, see section
    42(c) of Pub. L. 85-866, set out as a note under section 904 of
    this title.
      Amendment by section 83(b), (c) of Pub. L. 85-866 applicable only
    in respect of overpayments credited after Dec. 31, 1957, see
    section 83(d) of Pub. L. 85-866, set out as a note under section
    6601 of this title.

      NO INTEREST ON INDIVIDUAL INCOME TAX REFUNDS FOR 1974 REFUNDED
                   WITHIN 60 DAYS AFTER RETURN IS FILED
      Pub. L. 94-12, title I, Sec. 101(b), Mar. 29, 1975, 89 Stat. 28,
    as amended by Pub. L. 99-514, Sec. 2, Oct. 22, 1986, 100 Stat.
    2095, provided that: "In applying section 6611(e) of the Internal
    Revenue Code of 1986 [formerly I.R.C. 1954] (relating to income tax
    refund within 45 days after return is filed) in the case of any
    overpayment of tax imposed by subtitle A of such Code by an
    individual (other than an estate or trust and other than a
    nonresident alien individual) for a taxable year beginning in 1974,
    '60 days' shall be substituted for '45 days' each place it appears
    in such section 6611(e)."

-End-



-CITE-
    26 USC Sec. 6612                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter B - Interest on Overpayments

-HEAD-
    Sec. 6612. Cross references

-STATUTE-
    (a) Interest on judgments for overpayments
          For interest on judgments for overpayments, see 28 U.S.C.
        2411(a).
    (b) Adjustments
          For provisions prohibiting interest on certain adjustments in
        tax, see section 6413(a).
    (c) Other restrictions on interest
          For other restrictions on interest, see 2014(e) (!1)
        (relating to refunds attributable to foreign tax credits), 6412
        (relating to floor stock refunds), 6413(d) (relating to taxes
        under the Federal Unemployment Tax Act), 6416 (relating to
        certain taxes on sales and services), 6419 (relating to the
        excise tax on wagering), and 6420 (relating to payments in the
        case of gasoline used on the farm for farming purposes), and
        6421 (relating to payments in the case of gasoline used for
        certain nonhighway purposes or by local transit systems).


-SOURCE-
    (Aug. 16, 1954, ch. 736, 68A Stat. 820; Apr. 2, 1956, ch. 160, Sec.
    4(f), 70 Stat. 91; June 29, 1956, ch. 462, title II, Sec.
    208(e)(7), 70 Stat. 397; Pub. L. 107-16, title V, Sec. 532(c)(12),
    June 7, 2001, 115 Stat. 75.)


-STATAMEND-
                           AMENDMENT OF SECTION                       
      For termination of amendment by section 901 of Pub. L. 107-16,
    see Effective and Termination Dates of 2001 Amendment note below.

-REFTEXT-
                            REFERENCES IN TEXT                        
      The Federal Unemployment Tax Act, referred to in subsec. (c), is
    act Aug. 16, 1954, ch. 736, Secs. 3301 to 3311, 68A Stat. 454, as
    amended, which is classified generally to chapter 23 (Sec. 3301 et
    seq.) of this title. For complete classification of this Act to the
    Code, see section 3311 of this title and Tables.


-MISC1-
                                AMENDMENTS                            
      2001 - Subsec. (c). Pub. L. 107-16, Secs. 532(c)(12), 901,
    temporarily struck out "section 2011(c) (relating to refunds due to
    credit for State taxes)," after "see". See Effective and
    Termination Dates of 2001 Amendment note below.
      1956 - Subsec. (c). Act June 29, 1956, inserted reference to
    section 6421 of this title.
      Act Apr. 2, 1956, inserted reference to section 6420 of this
    title.

             EFFECTIVE AND TERMINATION DATES OF 2001 AMENDMENT         
      Amendment by Pub. L. 107-16 applicable to estates of decedents
    dying, and generation-skipping transfers, after Dec. 31, 2004, see
    section 532(d) of Pub. L. 107-16, set out as a note under section
    2011 of this title.
      Amendment by Pub. L. 107-16 inapplicable to estates of decedents
    dying, gifts made, or generation skipping transfers, after Dec. 31,
    2010, and the Internal Revenue Code of 1986 to be applied and
    administered to such estates, gifts, and transfers as if such
    amendment had never been enacted, see section 901 of Pub. L. 107-
    16, set out as a note under section 1 of this title.

                     EFFECTIVE DATE OF 1956 AMENDMENT                 
      Amendment by act June 29, 1956, effective June 29, 1956, see
    section 211 of act June 29, 1956, set out as an Effective Date note
    under section 4041 of this title.

-FOOTNOTE-
    (!1) So in original. Probably should be preceded by "sections".


-End-


-CITE-
    26 USC Subchapter C - Determination of Interest Rate;
           Compounding of Interest                         01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter C - Determination of Interest Rate; Compounding of
                    Interest                    

-HEAD-
       SUBCHAPTER C - DETERMINATION OF INTEREST RATE; COMPOUNDING OF
                                 INTEREST

-MISC1-
    Sec.                                                     
    6621.       Determination of rate of interest.                    
    6622.       Interest compounded daily.                            

                                AMENDMENTS                            
      1982 - Pub. L. 97-248, title III, Sec. 344(b)(3)(A), Sept. 3,
    1982, 96 Stat. 636, inserted "; Compounding of Interest" after
    "Rate" in heading for subchapter C.
      Pub. L. 97-248, title III, Sec. 344(b)(2), Sept. 3, 1982, 96
    Stat. 636, added item 6622.

-End-



-CITE-
    26 USC Sec. 6621                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter C - Determination of Interest Rate; Compounding of
                    Interest                    

-HEAD-
    Sec. 6621. Determination of rate of interest

-STATUTE-
    (a) General rule
      (1) Overpayment rate
        The overpayment rate established under this section shall be
      the sum of - 
          (A) the Federal short-term rate determined under subsection
        (b), plus
          (B) 3 percentage points (2 percentage points in the case of a
        corporation).

      To the extent that an overpayment of tax by a corporation for any
      taxable period (as defined in subsection (c)(3), applied by
      substituting "overpayment" for "underpayment") exceeds $10,000,
      subparagraph (B) shall be applied by substituting "0.5 percentage
      point" for "2 percentage points".
      (2) Underpayment rate
        The underpayment rate established under this section shall be
      the sum of - 
          (A) the Federal short-term rate determined under subsection
        (b), plus
          (B) 3 percentage points.
    (b) Federal short-term rate
      For purposes of this section - 
      (1) General rule
        The Secretary shall determine the Federal short-term rate for
      the first month in each calendar quarter.
      (2) Period during which rate applies
        (A) In general
          Except as provided in subparagraph (B), the Federal short-
        term rate determined under paragraph (1) for any month shall
        apply during the first calendar quarter beginning after such
        month.
        (B) Special rule for individual estimated tax
          In determining the addition to tax under section 6654 for
        failure to pay estimated tax for any taxable year, the Federal
        short-term rate which applies during the 3rd month following
        such taxable year shall also apply during the first 15 days of
        the 4th month following such taxable year.
      (3) Federal short-term rate
        The Federal short-term rate for any month shall be the Federal
      short-term rate determined during such month by the Secretary in
      accordance with section 1274(d). Any such rate shall be rounded
      to the nearest full percent (or, if a multiple of  1/2  of 1
      percent, such rate shall be increased to the next highest full
      percent).
    (c) Increase in underpayment rate for large corporate underpayments
      (1) In general
        For purposes of determining the amount of interest payable
      under section 6601 on any large corporate underpayment for
      periods after the applicable date, paragraph (2) of subsection
      (a) shall be applied by substituting "5 percentage points" for "3
      percentage points".
      (2) Applicable date
        For purposes of this subsection - 
        (A) In general
          The applicable date is the 30th day after the earlier of - 
            (i) the date on which the 1st letter of proposed deficiency
          which allows the taxpayer an opportunity for administrative
          review in the Internal Revenue Service Office of Appeals is
          sent, or
            (ii) the date on which the deficiency notice under section
          6212 is sent.

        The preceding sentence shall be applied without regard to any
        such letter or notice which is withdrawn by the Secretary.
        (B) Special rules
          (i) Nondeficiency procedures
            In the case of any underpayment of any tax imposed by this
          title to which the deficiency procedures do not apply,
          subparagraph (A) shall be applied by taking into account any
          letter or notice provided by the Secretary which notifies the
          taxpayer of the assessment or proposed assessment of the tax.
          (ii) Exception where amounts paid in full
            For purposes of subparagraph (A), a letter or notice shall
          be disregarded if, during the 30-day period beginning on the
          day on which it was sent, the taxpayer makes a payment equal
          to the amount shown as due in such letter or notice, as the
          case may be.
          (iii) Exception for letters or notices involving small
            amounts
            For purposes of this paragraph, any letter or notice shall
          be disregarded if the amount of the deficiency or proposed
          deficiency (or the assessment or proposed assessment) set
          forth in such letter or notice is not greater than $100,000
          (determined by not taking into account any interest,
          penalties, or additions to tax).
      (3) Large corporate underpayment
        For purposes of this subsection - 
        (A) In general
          The term "large corporate underpayment" means any
        underpayment of a tax by a C corporation for any taxable period
        if the amount of such underpayment for such period exceeds
        $100,000.
        (B) Taxable period
          For purposes of subparagraph (A), the term "taxable period"
        means - 
            (i) in the case of any tax imposed by subtitle A, the
          taxable year, or
            (ii) in the case of any other tax, the period to which the
          underpayment relates.
    (d) Elimination of interest on overlapping periods of tax
      overpayments and underpayments
      To the extent that, for any period, interest is payable under
    subchapter A and allowable under subchapter B on equivalent
    underpayments and overpayments by the same taxpayer of tax imposed
    by this title, the net rate of interest under this section on such
    amounts shall be zero for such period.

-SOURCE-
    (Added Pub. L. 93-625, Sec. 7(a)(1), Jan. 3, 1975, 88 Stat. 2114;
    amended Pub. L. 94-455, title XIX, Sec. 1906(b)(13)(A), Oct. 4,
    1976, 90 Stat. 1834; Pub. L. 96-167, Sec. 4(b), Dec. 29, 1979, 93
    Stat. 1275; Pub. L. 97-34, title VII, Sec. 711(a)-(c), Aug. 13,
    1981, 95 Stat. 340; Pub. L. 97-248, title III, Sec. 345(a), Sept.
    3, 1982, 96 Stat. 636; Pub. L. 98-369, div. A, title I, Sec.
    144(a), July 18, 1984, 98 Stat. 682; Pub. L. 99-514, title XV,
    Secs. 1511(a), (c)(1), 1535(a), Oct. 22, 1986, 100 Stat. 2744,
    2750; Pub. L. 100-647, title I, Sec. 1015(d), Nov. 10, 1988, 102
    Stat. 3569; Pub. L. 101-239, title VII, Sec. 7721(b), Dec. 19,
    1989, 103 Stat. 2399; Pub. L. 101-508, title XI, Sec. 11341(a),
    Nov. 5, 1990, 104 Stat. 1388-470; Pub. L. 103-465, title VII, Sec.
    713(a), Dec. 8, 1994, 108 Stat. 5001; Pub. L. 104-188, title I,
    Sec. 1702(c)(6), (7), Aug. 20, 1996, 110 Stat. 1870; Pub. L. 105-
    34, title XIV, Sec. 1463(a), title XVI, Sec. 1604(b)(1), Aug. 5,
    1997, 111 Stat. 1057, 1097; Pub. L. 105-206, title III, Secs.
    3301(a), 3302(a), July 22, 1998, 112 Stat. 741.)


-MISC1-
                                AMENDMENTS                            
      1998 - Subsec. (a)(1)(B). Pub. L. 105-206, Sec. 3302(a), amended
    subpar. (B) generally. Prior to amendment, subpar. (B) read as
    follows: "2 percentage points."
      Subsec. (d). Pub. L. 105-206, Sec. 3301(a), added subsec. (d).
      1997 - Subsec. (a)(1). Pub. L. 105-34, Sec. 1604(b)(1),
    substituted "subsection (c)(3), applied by substituting
    'overpayment' for 'underpayment')" for "subsection (c)(3))" in
    concluding provisions.
      Subsec. (c)(2)(B)(iii). Pub. L. 105-34, Sec. 1463(a), added cl.
    (iii).
      1996 - Subsec. (c)(2)(A). Pub. L. 104-188, Sec. 1702(c)(6),
    inserted closing provisions "The preceding sentence shall be
    applied without regard to any such letter or notice which is
    withdrawn by the Secretary."
      Subsec. (c)(2)(B)(i). Pub. L. 104-188, Sec. 1702(c)(7),
    substituted "this title" for "this subtitle".
      1994 - Subsec. (a)(1). Pub. L. 103-465 inserted concluding
    provisions.
      1990 - Subsec. (c). Pub. L. 101-508 added subsec. (c).
      1989 - Subsec. (c). Pub. L. 101-239 repealed subsec. (c) which
    related to attribution of interest on substantial underpayments to
    tax motivated transactions.
      1988 - Subsec. (a)(1)(A), (2)(A). Pub. L. 100-647, Sec.
    1015(d)(1), substituted "Federal short-term" for "short-term
    Federal".
      Subsec. (b). Pub. L. 100-647, Sec. 1015(d)(2), substituted
    "Federal short-term" for "short-term Federal" in heading.
      Subsec. (b)(1). Pub. L. 100-647, Sec. 1015(d)(1), substituted
    "Federal short-term" for "short-term Federal".
      1986 - Subsec. (a). Pub. L. 99-514, Sec. 1511(a), added subsec.
    (a) and struck out former subsec. (a) which read as follows: "The
    annual rate established under this section shall be such adjusted
    rate as is established by the Secretary under subsection (b)."
      Subsec. (b). Pub. L. 99-514, Sec. 1511(a), added subsec. (b)
    relating to determination of Federal short-term rate and struck out
    former subsec. (b) which related to interest rate adjustments and
    establishment of adjusted rates.
      Subsec. (c). Pub. L. 99-514, Sec. 1511(a), (c)(1), redesignated
    subsec. (d) as (c), in par. (1), struck out "annual" before "rate
    of interest" and substituted "the underpayment rate established
    under this section" for "the adjusted rate established under
    subsection (b)", and struck out former subsec. (c) definition of
    prime rate, which read as follows: "For purposes of subsection (b),
    the term 'adjusted prime rate charged by banks' means the average
    predominant prime rate quoted by commercial banks to large
    businesses, as determined by the Board of Governors of the Federal
    Reserve System."
      Subsec. (c)(3)(A)(v). Pub. L. 99-514, Sec. 1535(a), added cl.
    (v).
      Subsec. (d). Pub. L. 99-514, Sec. 1511(c)(1)(A), redesignated
    subsec. (d) as (c).
      1984 - Subsec. (d). Pub. L. 98-369 added subsec. (d).
      1982 - Subsec. (b). Pub. L. 97-248 substituted provisions that if
    the adjusted prime rate charged by banks (rounded to the nearest
    full percent) during the 6-month period ending on September 30 of
    any calendar year, or during the 6-month period ending on March 31
    of any calendar year, differs from the interest rate in effect
    under this section on either such date, respectively, then the
    Secretary shall establish, within 15 days after the close of the
    applicable 6-month period, an adjusted rate of interest equal to
    such adjusted prime rate, and that any adjusted rate of interest
    established under paragraph (1) shall become effective on January 1
    of the succeeding year in the case of an adjustment attributable to
    paragraph (1)(A), and on July 1 of the same year in the case of an
    adjustment attributable to paragraph (1)(B), for provisions that
    the Secretary was to establish an adjusted rate of interest for the
    purpose of subsection (a) not later than October 15 of any year if
    the adjusted prime rate charged by banks during September of that
    year, rounded to the nearest full percent, was at least a full
    percentage point more or less than the interest rate which was then
    in effect, and that any such adjusted rate of interest would be
    equal to the adjusted prime rate charged by banks, rounded to the
    nearest full percent, and would become effective on January 1 of
    the immediately succeeding year.
      1981 - Subsec. (b). Pub. L. 97-34, Sec. 711(a), struck out
    provision that an adjustment provided for under this subsection not
    be made prior to the expiration of 23 months following the date of
    any preceding adjustment under this subsection which changes the
    rate of interest.
      Pub. L. 97-34, Sec. 711(c), substituted "January 1" for "February
    1".
      Subsec. (c). Pub. L. 97-34, Sec. 711(b), struck out "90 percent
    of" before "the average predominant prime rate".
      1979 - Subsec. (a). Pub. L. 96-167 substituted provisions setting
    the annual rate established under this section to be such adjusted
    rate as is established by the Secretary under subsec. (b) of this
    section for provision that the rate of interest under sections
    6601(a), 6602, 6611(a), 6332(c)(1), and 7426(g) of this title, and
    under section 2411(a) of title 28 was to be 9 percent per annum, or
    such adjusted rate as was established by the Secretary under
    subsection (b).
      1976 - Subsecs. (a), (b). Pub. L. 94-455 struck out "or his
    delegate" after "Secretary".

                     EFFECTIVE DATE OF 1998 AMENDMENT                 
      Amendment by section 3301(a) of Pub. L. 105-206 applicable to
    interest for periods beginning after July 22, 1998, and, subject to
    applicable statutes of limitation, to interest for periods
    beginning before July 22, 1998, if taxpayer reasonably identifies
    and establishes periods of overpayments and underpayments for which
    zero rate applies, and not later than Dec. 31, 1999, requests
    application of subsec. (d) of this section to such periods, see
    section 3301(c) of Pub. L. 105-206, set out as a note under section
    6601 of this title.
      Pub. L. 105-206, title III, Sec. 3302(b), July 22, 1998, 112
    Stat. 742, provided that: "The amendment made by this section
    [amending this section] shall apply to interest for the second and
    succeeding calendar quarters beginning after the date of the
    enactment of this Act [July 22, 1998]."

                     EFFECTIVE DATE OF 1997 AMENDMENT                 
      Section 1463(b) of Pub. L. 105-34 provided that: "The amendment
    made by subsection (a) [amending this section] shall apply for
    purposes of determining interest for periods after December 31,
    1997."
      Amendment by section 1604(b)(1) of Pub. L. 105-34 effective as if
    included in the sections of the Uruguay Round Agreements Act, Pub.
    L. 103-465, to which it relates, see section 1604(b)(4) of Pub. L.
    105-34, set out as a note under section 412 of this title.

                     EFFECTIVE DATE OF 1996 AMENDMENT                 
      Amendment by Pub. L. 104-188 effective, except as otherwise
    expressly provided, as if included in the provision of the Revenue
    Reconciliation Act of 1990, Pub. L. 101-508, title XI, to which
    such amendment relates, see section 1702(i) of Pub. L. 104-188, set
    out as a note under section 38 of this title.

                     EFFECTIVE DATE OF 1994 AMENDMENT                 
      Section 713(b) of Pub. L. 103-465 provided that: "The amendment
    made by this section [amending this section] shall apply for
    purposes of determining interest for periods after December 31,
    1994."

                     EFFECTIVE DATE OF 1990 AMENDMENT                 
      Section 11341(b) of Pub. L. 101-508 provided that: "The amendment
    made by subsection (a) [amending this section] shall apply for
    purposes of determining interest for periods after December 31,
    1990."

                     EFFECTIVE DATE OF 1989 AMENDMENT                 
      Amendment by Pub. L. 101-239 applicable to returns the due date
    for which (determined without regard to extensions) is after Dec.
    31, 1989, see section 7721(d) of Pub. L. 101-239, set out as a note
    under section 461 of this title.

                     EFFECTIVE DATE OF 1988 AMENDMENT                 
      Amendment by Pub. L. 100-647 effective, except as otherwise
    provided, as if included in the provision of the Tax Reform Act of
    1986, Pub. L. 99-514, to which such amendment relates, see section
    1019(a) of Pub. L. 100-647, set out as a note under section 1 of
    this title.

                     EFFECTIVE DATE OF 1986 AMENDMENT                 
      Amendment by section 1511(a), (c)(1) of Pub. L. 99-514 applicable
    for purposes of determining interest for periods after Dec. 31,
    1986, see section 1511(d) of Pub. L. 99-514, set out as a note
    under section 47 of this title.
      Section 1535(b) of Pub. L. 99-514 provided that: "The amendment
    made by subsection (a) [amending this section] shall apply to
    interest accruing after December 31, 1984; except that such
    amendment shall not apply in the case of any underpayment with
    respect to which there was a final court decision before the date
    of the enactment of this Act [Oct. 22, 1986]."

                     EFFECTIVE DATE OF 1984 AMENDMENT                 
      Section 144(c) of Pub. L. 98-369 provided that: "The amendments
    made by this section [amending this section and section 6214 of
    this title] shall apply with respect to interest accruing after
    December 31, 1984."

                     EFFECTIVE DATE OF 1982 AMENDMENT                 
      Section 345(b) of Pub. L. 97-248, as amended by Pub. L. 98-369,
    div. A, title VII, Sec. 714(m), July 18, 1984, 98 Stat. 963,
    provided that: "The amendment made by this section [amending this
    section] shall apply to adjustments taking effect on or after
    January 1, 1983."

                     EFFECTIVE DATE OF 1981 AMENDMENT                 
      Section 711(d) of Pub. L. 97-34 provided that:
      "(1) For subsections (a) and (b). - The amendments made by
    subsections (a) and (b) [amending this section] shall apply to
    adjustments made after the date of the enactment of this Act [Aug.
    13, 1981].
      "(2) For subsection (c). - The amendment made by subsection (c)
    [amending this section] shall apply to adjustments made for periods
    after 1982."

                     EFFECTIVE DATE OF 1979 AMENDMENT                 
      Section 4(c)(2) of Pub. L. 96-167 provided that: "The amendment
    made by subsection (b) [amending this section] shall take effect on
    the date of the enactment of this Act [Dec. 29, 1979]."

                              EFFECTIVE DATE                          
      Section 7(e) of Pub. L. 93-625 provided that: "The amendments
    made by this section [enacting this section and amending sections
    514, 6163, 6166, 6167, 6332, 6504, 6601, 6602, 6611, 6654, 6655,
    and 7426 of this title and section 2411 of Title 28, Judiciary and
    Judicial Procedure] shall take effect on July 1, 1975, and apply to
    amounts outstanding on such date or arising thereafter."

                                REGULATIONS                            
      Section 1511(b) of Pub. L. 99-514 provided that: "The Secretary
    of the Treasury or his delegate may issue regulations to coordinate
    section 6621 of the Internal Revenue Code of 1954 [now 1986] (as
    amended by this section) with section 6601(f) of such Code. Such
    regulations shall not apply to any period after the date 3 years
    after the date of the enactment of this Act [Oct. 22, 1986]."

-End-



-CITE-
    26 USC Sec. 6622                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter C - Determination of Interest Rate; Compounding of
                    Interest                    

-HEAD-
    Sec. 6622. Interest compounded daily

-STATUTE-
    (a) General rule
      In computing the amount of any interest required to be paid under
    this title or sections 1961(c)(1) or 2411 of title 28, United
    States Code, by the Secretary or by the taxpayer, or any other
    amount determined by reference to such amount of interest, such
    interest and such amount shall be compounded daily.
    (b) Exception for penalty for failure to file estimated tax
      Subsection (a) shall not apply for purposes of computing the
    amount of any addition to tax under section 6654 or 6655.

-SOURCE-
    (Added Pub. L. 97-248, title III, Sec. 344(a), Sept. 3, 1982, 96
    Stat. 635.)


-MISC1-
                              EFFECTIVE DATE                          
      Section 344(c) of Pub. L. 97-248 provided that: "The amendments
    made by this section [enacting this section and amending section
    6601 of this title] shall apply to interest accruing after December
    31, 1982."

-End-


-CITE-
    26 USC Subchapter D - Notice Requirements                   01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter D - Notice Requirements

-HEAD-
                    SUBCHAPTER D - NOTICE REQUIREMENTS                

-MISC1-
    Sec.                                                     
    6631.       Notice requirements.                                  

                                AMENDMENTS                            
      2000 - Pub. L. 106-554, Sec. 1(a)(7) [title III, Sec. 319(22)],
    Dec. 21, 2000, 114 Stat. 2763, 2763A-647, substituted
    "Requirements" for "requirements" in subchapter heading.

-End-



-CITE-
    26 USC Sec. 6631                                            01/03/2007

-EXPCITE-
    TITLE 26 - INTERNAL REVENUE CODE
    Subtitle F - Procedure and Administration
    CHAPTER 67 - INTEREST
    Subchapter D - Notice Requirements

-HEAD-
    Sec. 6631. Notice requirements

-STATUTE-
      The Secretary shall include with each notice to an individual
    taxpayer which includes an amount of interest required to be paid
    by such taxpayer under this title information with respect to the
    section of this title under which the interest is imposed and a
    computation of the interest.

-SOURCE-
    (Added Pub. L. 105-206, title III, Sec. 3308(a), July 22, 1998, 112
    Stat. 745.)


-MISC1-
                              EFFECTIVE DATE                          
      Pub. L. 105-206, title III, Sec. 3308(c), July 22, 1998, 112
    Stat. 745, as amended by Pub. L. 106-554, Sec. 1(a)(7) [title III,
    Sec. 302(c)], Dec. 21, 2000, 114 Stat. 2763, 2763A-632, provided
    that: "The amendments made by this section [enacting this
    subchapter] shall apply to notices issued after June 30, 2001. In
    the case of any notice issued after June 30, 2001, and before July
    1, 2003, to which section 6631 of the Internal Revenue Code of 1986
    applies, the requirements of section 6631 of such Code shall be
    treated as met if such notice contains a telephone number at which
    the taxpayer can request a copy of the taxpayer's payment history
    relating to interest amounts included in such notice."

-End-