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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
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.
* * * * * * *
(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
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