- 3 - 6621(a)(1). In other words, petitioner seeks interest to exceed the Federal short-term rate by 3 percent instead of 0.5 percent. Section 6621(a)(1) provides: SEC. 6621. DETERMINATION OF RATE OF INTEREST. (a) General Rule.-- (1) Overpayment rate.--The overpayment rate established under this section shall be the sum of–- (A) the Federal short-term rate determined under subsection (b), plus (B) 3 percentage points (2 percentage points in the case of a corporation). To the extent that an overpayment of tax by a corporation for any taxable period (as defined in subsection (c)(3), applied by substituting “overpayment” for “underpayment”) exceeds $10,000, subparagraph (B) shall be applied by substituting “0.5 percentage point” for “2 percentage points”. The gist of this dispute is the cross-reference to subsection (c)(3). Subsection (c)(3) provides: (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–Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011