Net Rate Interest Netting - Overpaid Estimated Taxes

ID: CCA_2011042616302342 Number: 201121017
Release Date: 5/27/2011
Office: ---
UILC: 6621.05-00
From: ---
Sent: Tuesday, April 26, 2011 4:30:24 PM
To: ---
Cc:
Subject: RE: Interest netting
The Service does not currently have the ability to automatically apply the net rate of zero in §
6621(d). Congress recognized this current limitation and intended that until such time as procedures are implemented that allow for the automatic application of § 6621(d) by the Service, the Service will promptly and carefully consider any taxpayer's request to have interest charges recalculated in accordance with § 6621(d). See H. R. Rep. No. 364 (Part 1), 105th Cong., 1st Sess. 64 (1998); S. Rep. No. 174, 105th Cong., 2d Sess. 62 (1998).
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