§6622 — Interest compounded daily
15 citing cases
Statute Text — 26 U.S.C. §6622
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.
Subsection (a) shall not apply for purposes of computing the amount of any addition to tax under section 6654 or 6655.
Treasury Regulations
-
Treas. Reg. §301.6622-1Interest compounded daily
(a) General rule. Effective for interest accruing after December 31, 1982, in computing the amount of any interest required to be paid under the Internal Revenue Code of 1954 or sections 1961(c)(1) or 2411 of title 28, United States Code, by the Commissioner or by the taxpayer, or in computing any other amount determined by reference to such amount of interest, or by reference to the interest rate established under section 6621, such interest or such other amount shall be compounded daily by dividing such rate of interest by 365 (366 in a leap year) and compounding such daily interest rate each day.
(b) Exception. Paragraph (a) of this section shall not apply for purposes of determining the amount of any addition to tax under sections 6654 or 6655 (relating to failure to pay estimated income tax).
(c) Applicability to unpaid amounts on December 31, 1982—(1) In general. The unpaid interest (or other amount) that shall be compounded daily includes the interest (or other amount) accrued but unpaid on December 31, 1982.
(2) Illustration. The provisions of this (c) may be illustrated by the following example.
-
Treas. Reg. §301.6622-1(a)General rule.
General rule. Effective for interest accruing after December 31, 1982, in computing the amount of any interest required to be paid under the Internal Revenue Code of 1954 or sections 1961(c)(1) or 2411 of title 28, United States Code, by the Commissioner or by the taxpayer, or in computing any other amount determined by reference to such amount of interest, or by reference to the interest rate established under section 6621, such interest or such other amount shall be compounded daily by dividing such rate of interest by 365 (366 in a leap year) and compounding such daily interest rate each day.
-
Treas. Reg. §301.6622-1(b)Exception.
Exception. Paragraph (a) of this section shall not apply for purposes of determining the amount of any addition to tax under sections 6654 or 6655 (relating to failure to pay estimated income tax).
-
Treas. Reg. §301.6622-1(c)Applicability to unpaid amounts on December 31, 1982—(1) In general.
Applicability to unpaid amounts on December 31, 1982—(1) In general. The unpaid interest (or other amount) that shall be compounded daily includes the interest (or other amount) accrued but unpaid on December 31, 1982.
(2) Illustration. The provisions of this (c) may be illustrated by the following example.
15 Citing Cases
y paid thejoint income tax deficiencies that were determined in the prior tax court decision. Regarding the Income Tax accounts, you now owe only penalties under IRC§ 6651(a)(2) and interest due under IRC §6601(a) & (b), IRC§6621(a)(2) [sic] and IRC§6622 [sic]. You have fully paid the IRC 6663(a) [sic] penalty amounts and now owe only interest due under IRC §6601(a) & (b), IRC§6621(a)(2) [sic] and IRC§6622 [sic]. You have claimed IRS should not collect any interest on the deficien- cies as deter
Section 6622 provides that in computing the amount .of interest required to be paid under section 6611, the interest will be compounded daily. . Section 6621 provides that the rate of interest to be paid by_ respondent to corporate taxpayers on overpayments shall be the·sum of the Federal short-term interest rate, as calculated according to the for
6611 requires us to reject GE’s theory of the case”. Id. at 1311-1312. As we shall discuss, petitioner believes this analysis by the Court of Appeals for the Federal Circuit is flawed because “overpayment” does not include interest compounded under section 6622. Petitioner challenges the holding of the Court of Appeals for the Federal Circuit by arguing that the phrase “overpayment of tax” in section 6621(a) limits the scope of the change in corporate interest rates to the overpayment itself, t
Section 6622 provides that in computing the amount of interest required to be paid under section 6611, the interest will be compounded daily.
Section 6622 provides that in computing the amount of interest required to be paid under section 6611, the interest will be compounded daily. Section 6621 provides that the rate of interest to be paid by respondent to corporate taxpayers on overpayments shall be the sum of the Federal short-term interest rate, as calculated according to the formula
Section 6622 provides that in computing the amount of interest required to be paid under section 6611, the interest will be compounded daily. Section 6621 provides that the rate of interest to be paid by respondent to corporate taxpayers on overpayments shall be the sum of the Federal short-term interest rate, as calculated according to the formula
6611 requires us to reject GE’s theory of the case”. Id. at 1311-1312. As we shall discuss, petitioner believes this analysis by the Court of Appeals for the Federal Circuit is flawed because “overpayment” does not include interest compounded under section 6622. Petitioner challenges the holding of the Court of Appeals for the Federal Circuit by arguing that the phrase “overpayment of tax” in section 6621(a) limits the scope of the change in corporate interest rates to the overpayment itself, t
issioner, supra. There can be no abuse of discretion by the Commissioner for failure to abate interest if the statute that applies does not give the Commissioner discretion to abate the interest. Interest on the interest compounds daily pursuant to section 6622. The interest accruing from May 1, 1999, to the date of payment was not caused by any delay by the Internal Revenue Service, is authorized by statute, and is due and owing from petitioner. The failure to abate that interest was not an abu