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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