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               SEC. 6621(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 rate.--For purposes of this                        
                         (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.                                                
                        *     *     *     *     *     *     *                         
                    (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                              
                         (B) Taxable period.--For purposes of                         
                    subparagraph (A), the term "taxable period"                       
                              (i) in the case of any tax                              

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Last modified: May 25, 2011