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such interest in a supplemental proceeding commenced pursuant to
section 7481(c) and Rule 261.
Section 6601(a) provides the general rule that interest will
be imposed at the rate established under section 6621 on any tax
that is not paid on or before the last date prescribed for
payment. Section 6621(a)(2) provides the general rule that the
underpayment rate shall be the sum of the Federal short-term rate
determined under section 6221(b) plus 3 percentage points.
Section 6621(c), which was enacted in its present form by
section 11341(a) of the Omnibus Budget Reconciliation Act of
1990, Pub. L. 101-508, 104 Stat. 1388, effective for purposes of
determining interest for periods after December 31, 1990, sets
forth the rules for determining the amount of interest payable
under section 6601 on large corporate underpayments of tax. As
relevant herein, section 6621(c) provides that interest shall be
computed on an underpayment of tax by a C corporation that
exceeds $100,000 at an increased rate equal to the Federal short-
term rate determined under section 6621(b) plus 5 percentage
points. The computation of interest under section 6621(c) is
applicable for periods after the 30th day after the earlier of
(1) the date of mailing of the first letter of proposed
deficiency which allows the taxpayer the opportunity for the IRS
Appeals Office review, or (2) the date of mailing of a notice of
deficiency under section 6212.
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Last modified: May 25, 2011