The Department of Labor gave Sea Sprite an opportunity for an evidentiary hearing, and, as our first opinion stresses, the Department's order of April 1989 was a final resolu- tion of the dispute. Under 29 U.S.C. sec. Under the Debt Collec- tion Act an agency may make this explicit, see 31 U.S.C. sec. Although we can't think of any reason to withhold inter- est during the period between imposition and enforcement of a penalty, several reasons support interest. The parallel to an appeal is one.
Inflation is another.
Still a third reason is the desire to promote compliance and reduce demands on the judicial system. If interest does not commence until the court of appeals enforces the award, then rational businesses will refuse to pay. Forcing the Secretary to commence judicial proceedings does a disservice to other persons, who must wait in a longer queue for judges' attention. Finally, interest during the period between assessment and enforcement compen- sates the United States for the risk of nonpayment, a risk that turned out to be substantial in this case. Federal courts exercising com- mon law powers have found these reasons adequate to create a strong presumption in favor of interest, even when equitable considerations seem to look the other way.