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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

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▸Contents — Internal Revenue Manual Part 8. Appeals

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