Code of Federal Regulations · Section
§ 301.6622-1 — -1 Interest Compounded Daily
26 C.F.R. § 301.6622-1
(a) General rule. Effective for interest accruing after December 31, 1982, in computing the amount of any interest required to be paid under the Internal Revenue Code of 1954 or sections 1961(c)(1) or 2411 of title 28, United States Code, by the Commissioner or by the taxpayer, or in computing any other amount determined by reference to such amount of interest, or by reference to the interest rate established under section 6621, such interest or such other amount shall be compounded daily by dividing such rate of interest by 365 (366 in a leap year) and compounding such daily interest rate each day.
(b) Exception. Paragraph (a) of this section shall not apply for purposes of determining the amount of any addition to tax under sections 6654 or 6655 (relating to failure to pay estimated income tax).
(c) Applicability to unpaid amounts on December 31, 1982—(1) In general. The unpaid interest (or other amount) that shall be compounded daily includes the interest (or other amount) accrued but unpaid on December 31, 1982.
(2) Illustration. The provisions of this (c) may be illustrated by the following example.
Individual A files a tax return for calendar year 1981 on April 15, 1982, showing a tax due of $10,000. A pays $10,000 on December 31, 1982, but A does not pay any interest with respect to this underpayment until March 1, 1983, on which date A paid all amounts of interest with respect to the $10,000 underpayment of tax. On December 31, 1982, A's unsatisfied interest liability was $1,424.66 ($10,000 × 20 percent × 260/365 days). Interest, compounded daily, accrues on this unsatisfied interest obligation beginning on January 1, 1983, until March 1, 1983, the date the total interest obligation is satisfied. On March 1, 1983, the total interest obligation is $1,462.62, computed as follows:
Authorizing Statute
-
Confidentiality and disclosure of returns and return information26 U.S.C. § 6103
-
Restrictions applicable to deficiencies; petition to Tax Court26 U.S.C. § 6213
-
Signing of returns and other documents26 U.S.C. § 6061
-
Assessment, collection, and payment26 U.S.C. § 6232
-
Period of limitations on making adjustments26 U.S.C. § 6235
-
Validity and priority against certain persons26 U.S.C. § 6323
-
Definitions26 U.S.C. § 7701
-
Partner’s return must be consistent with partnership return26 U.S.C. § 6222
-
Alternative to payment of imputed underpayment by partnership26 U.S.C. § 6226
-
Notice of qualification as executor or receiver26 U.S.C. § 6036
-
Partners bound by actions of partnership26 U.S.C. § 6223
-
Abatements26 U.S.C. § 6404
-
Commissioner of Internal Revenue; other officials26 U.S.C. § 7803
-
Extension of time for filing returns26 U.S.C. § 6081
-
Treaty-based return positions26 U.S.C. § 6114
-
Timely mailing treated as timely filing and paying26 U.S.C. § 7502
-
Interest and penalties26 U.S.C. § 6233
-
Certified professional employer organizations26 U.S.C. § 7705
-
Accelerated cost recovery system26 U.S.C. § 168
-
General requirement of return, statement, or list26 U.S.C. § 6011
-
Disclosure of reportable transactions26 U.S.C. § 6111
-
Rules and regulations26 U.S.C. § 7805
-
Persons required to make returns of income26 U.S.C. § 6012
-
Return of S corporation26 U.S.C. § 6037
-
Reimbursement to State and local law enforcement agencies26 U.S.C. § 7624
-
Determination at partnership level26 U.S.C. § 6221
-
Partnership adjustment by Secretary26 U.S.C. § 6225
-
Authority to release levy and return property26 U.S.C. § 6343
-
Disclosure or use of information by preparers of returns26 U.S.C. § 7216
-
Departmental regulations5 U.S.C. § 301
-
Tax imposed26 U.S.C. § 1
-
Notice of proceedings and adjustment26 U.S.C. § 6231
-
Payment of tax by commercially acceptable means26 U.S.C. § 6311
-
Sale of seized property26 U.S.C. § 6335
-
Procedural requirements26 U.S.C. § 6751
-
Low-income housing credit26 U.S.C. § 42
-
Special rules26 U.S.C. § 1474
-
Returns by exempt organizations26 U.S.C. § 6033
-
Definitions and special rules26 U.S.C. § 6241
-
Administrative appeal of liens26 U.S.C. § 6326
-
Expenses of detection of underpayments and fraud, etc.26 U.S.C. § 7623
-
Information concerning resident status26 U.S.C. § 6039E
-
Identifying numbers26 U.S.C. § 6109
-
Administrative adjustment request by partnership26 U.S.C. § 6227
-
Authority to make credits or refunds26 U.S.C. § 6402
-
Judicial review of partnership adjustment26 U.S.C. § 6234
-
Failure to file notice of redetermination of foreign tax26 U.S.C. § 6689
-
Income from discharge of indebtedness26 U.S.C. § 108