Refund of IRC 6603 Deposit - Amount in Dispute and Excess Amount Components From IRM…
Internal Revenue Manual Part 8. Appeals · 2026-10-03 edition · updated 2026-10-04 · United States
IRC 6603 Deposit Components
Component $ Amounts
Interest Bearing at the Federal Short-term Rate Yes/No
Disputed Tax Amount*
$10,000,000.00
Yes‡
Disputed Penalty Amount*
$ 2,000,000.00
Yes‡
Disputed Underpayment Interest Amount**
$ 1,500,000.00
Yes‡
Deposit in Excess of T/P/I Amount(s) in dispute**
$ 6,500,000.00
No
Total IRC 6603 Deposit
$20,000,000.00†
Refundable with mixture of interest bearing and non-interest bearing components
*ATE verifies and provides documentation to APS
** APS calculates the amount of underpayment interest attributable to the tax and penalty in dispute. APS then subtracts all disputed amounts (T/P/I) from the total 6603 Deposit $ amount to determine the excess deposit amount. The excess amount is refundable but is not interest bearing.
APS Calculates Overpayment (TC 770) Interest at the Federal short-term rate‡ on the amount = (T/P/I) and Prepares the Manual Refund
† Principle = $ 20,000,000.00
‡ TC 770 Interest = $ 25,000.00
Total Refund = $ 20,025,000.00
Get a plain-English answer with a citation back to this text.
Ask AI about this code