Ezel / IRS Rulings / 1121017
Chief Counsel Advice 1121017 Released May 27, 2011 Advice

CCA 1121017: taxpayers may request recalculation under the net interest rate rule

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This page covers one taxpayer's ruling from 2011, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2011
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel addressed the Service’s treatment of requests under IRC § 6621(d), which can produce a net interest rate of zero in certain overpayment and underpayment situations. The advice stated that the Service could not yet apply the zero rate automatically. It explained that Congress intended the Service to promptly and carefully consider a taxpayer’s request to have interest recalculated under § 6621(d) until automatic procedures were implemented.

Ruling snapshot

  • Question: How should the Service handle a request to recalculate interest under IRC § 6621(d) while automatic net-rate procedures are unavailable?
  • Outcome: Advice given.
  • Key authorities: IRC § 6621(d); H.R. Rep. No. 105-364 (Part 1), at 64 (1998); S. Rep. No. 105-174, at 62 (1998).

Full text (IRS public release)

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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