22. Department of the Treasury · Minor · Needs Congress
Equalize interest rates on tax overpayments and underpayments
Printed page 700 22. Department of the Treasury
“For example, interest on overpayments should be the same as interest on underpayments rather than the government receiving a higher rate, the time limit for taxpayers to sue for damages for improper collection actions should be extended, the jurisdiction of the Tax Court should be expanded, and the tax penalty system should be reformed by rationalizing the penalty structure and reducing some of the most punitive penalties.”
What has happened
- Not started
The rate differential in sections 6601 and 6621 stands: the overpayment rate for non-corporate taxpayers is still the federal short-term rate plus three points against an underpayment rate of the same, and corporate overpayments are still paid at a lower rate than corporate underpayments are charged. Public Law 119-21 did not amend section 6621, and no bill equalizing the two rates has passed either chamber. Of the four asks the tracker draws from this one sentence, only Tax Court jurisdiction (#1954) has moved.
No action found yet. This entry is the starting point, not a finding.
Research log
What was searched, and what didn’t count as evidence
Research notes
This Quote states four separate asks and the tracker splits them: interest equalization (this item), the time limit for damages suits (#1953), Tax Court jurisdiction (#1954) and penalty reform (#1955). They share the cluster negative search recorded in docs/research/ch-22.md.
H.R. 5346, the Fair and Accountable IRS Reviews Act, is titled “To amend the Internal Revenue Code of 1986 to reform certain penalty and interest provisions” and passed the House on 2025-12-01, but its operative text amends only section 6751(b)‘s supervisory-approval requirement — it changes no interest rate. Recorded here so the title is not mistaken for the substance.
- Action
- other
- Object
- interest rate on tax overpayments
- ID
- 1952