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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–
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