Tax time tension: interest calculations matter |
As the tax year approaches its end, taxpayers must focus on the complexities of interest calculations related to tax deficiencies and refunds. Mary McNulty, a partner at Holland & Knight, emphasizes that "computing interest on the tax deficiency or refund involves nuanced legal and procedural considerations." Recent cases, such as Pitney Bowes, Inc. v. United States, highlight the ongoing disputes over interest on overpayments and installment payments. Taxpayers are likely to continue filing returns reporting overpayments, and if the IRS does not pay overpayment interest, more lawsuits may arise. Additionally, the "same taxpayer" rule complicates interest netting, as seen in Bank of America Corp. v. United States. Taxpayers must navigate various forums for overpayment interest disputes, especially in light of adverse precedents. Lastly, the potential for interest suspensions due to COVID-19 adds another layer of complexity to tax planning.