§6622 — Interest compounded daily
15 cases·6 followed·9 cited—40% support
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. §Treas. Reg. §301.6622-1 Interest compounded daily
- Treas. Reg. §Treas. Reg. §301.6622-1(a) General rule.
- Treas. Reg. §Treas. Reg. §301.6622-1(b) Exception.
- Treas. Reg. §Treas. Reg. §301.6622-1(c) Applicability to unpaid amounts on December 31, 1982—(1) In general.
15 Citing Cases
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 for
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
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
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
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
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