Interest on Underpayment, Nonpayment, or Extensions of Time for Payment of Tax (Interest v. No Interest Imposed)

ID: CCA_2009100714421242 Number: 200947043
Release Date: 11/20/2009
Office: ---
UILC: 6601.00-00
From: ---
Sent: Wednesday, October 07, 2009 2:42:14 PM
To: ---
Cc: ---
Subject: interest on penalty
As we previously discussed by phone, I think interest on an estimated tax penalty accrues from the date of notice and demand if a taxpayer fails to pay the amount within 21 days of notice and demand (or 10 business days in certain cases.) See I.R.C. § 6601(e)(2)(A). I haven't located anything that would lead me to believe otherwise.