New Rulings Highlight Need to Review IRS Interest Computations

Tax attorneys Mary McNulty and Lee Meyercord co-authored a Bloomberg Tax article summarizing recent case law involving IRS interest computations for tax deficiencies and tax refunds. Their article analyzes Pitney Bowes, Inc. v. United States, which concerns interest on overpayments; Bank of America Corp. v. United States, which involves "interest netting" for overlapping underpayments and overpayments by the "same taxpayer" under Internal Revenue Code Section 6621(d); and Abdo v. Commissioner, which stems from interest suspension during the COVID-19 pandemic. Ms. McNulty and Ms. Meyercord identify the core issues at play in each case and highlight what practitioners should keep an eye out for as litigation continues.

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