INCOME TAX

Rev. Rul. 2006–49, page 584. Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 2006, will be 8 percent for overpayments (7 percent in the case of a corporation), 8 percent for underpayments, and 10 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 5.5 percent.

T.D. 9284, page 582. Final regulations under section 6502 of the Code incorporate changes imposed by the IRS Restructuring and Reform Act of 1988 that limit the IRS’s ability to enter into agreements extending the statute of limitations for collection.

REG–121509–00, page 602. Proposed regulations under sections 959, 961, and 1502 of the Code provide guidance relating to the exclusion from gross income of previously taxed earnings and profits under section 959 and related basis adjustments under section 961.

REG–148576–05, page 627. Proposed regulations under 31 USC 9701 increase the amount of the user fees imposed under regulations sections 300.1 and 300.2 for entering into and restructuring or reinstating installment agreements. The regulations bring the fees in line with the actual costs to the IRS. Currently, the IRS charges $43 for entering into an installment agreement and $24 for restructuring or reinstating an installment agreement that is in default. The IRS recently completed a review of the installment agreement program and determined that the full cost of an installment agreement is $105, and the full cost of restructuring or

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