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accrued interest on the overpayment to continue to receive the
regular interest rate, which is always 1.5 percent higher.
The role of the phrase “overpayment of tax” is central to
this dispute. We find the phrase in question is a device to
describe the occasion when the GATT rate is triggered for all
interest computational purposes including compounding under
section 6622. We do not read the phrase “overpayment of tax” as
a limitation on the scope of the applicability of the changed
rate once triggered. Given the role of section 6621 in the
statutory scheme for interest, we must reject petitioner’s
construction.
The role of section 6621 is to set interest rates which are
not constant but may change quarterly. Sec. 6621(b); sec.
301.6621-1(a)(3), Proced. & Admin. Regs. The GATT rate change is
described in public law as a change for purposes of determining
interest after December 31, 1994. Uruguay Round Agreements Act,
sec. 713, 108 Stat. 5001. This change from the regular rate
applies on its face to all applications of interest after
December 31, 1994, in situations when the GATT rate is triggered.
The language added to section 6621(a) triggers a change in
interest rate.
Sections 6611, 6621, and 6622 constitute the statutory
scheme to authorize interest on overpayments, set the rate of
interest, and provide for the method of computation,
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