[Code of Federal Regulations]
[Title 26, Volume 13]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR]

[Page 604-605]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
Procedure and Administration--Table of Contents
 
Sec.  1.9000-6  Provisions for the waiver of interest.

    (a) In general. If the statement is filed in accordance with Sec.  
1.9000-3 and if that portion of the increase in tax which is due before 
December 15, 1955 (without regard to any extension of time for payment 
and without regard to the provisions of Sec. Sec.  1.9000-2 to 1.9000-8, 
inclusive), is paid in full on or before such date, then no interest 
shall be due with respect to that amount. The provisions of this 
paragraph may be illustrated by the following example:

    Example. Corporation M's return for the calendar year 1954 was filed 
on March 15, 1955, and the tax liability shown thereon was paid in equal 
installments on March 15, 1955, and June 15, 1955. M filed a statement 
on December 15, 1955, showing the increase in its tax liability 
resulting from the repeal of sections 452 and 462 and paid at that time 
the increase in tax shown thereon. No interest will be imposed with 
respect to the amount of such payment.


Interest shall be computed under the applicable provisions of the 
internal revenue laws on any portion of the increase in tax shown on the 
statement which is due after December 15, 1955, and which is not paid 
when due.
    (b) Limitation on application of waiver. The provisions of paragraph 
(a) of this

[[Page 605]]

section shall not apply to any portion of the increase in tax shown on 
the statement if such increase reflects an amount in excess of that 
attributable solely to the repeal of sections 452 and 462, i. e., is 
attributable in whole or in part to excessive or unwarranted deferrals 
or accruals under section 452 or 462, as the case may be, in computing 
the tax liability with the application of such sections. Notwithstanding 
the preceding sentence, paragraph (a) of this section shall be 
applicable if the taxpayer can show that the tax liability as computed 
with the application of sections 452 and 462 is based upon a reasonable 
interpretation and application of such sections as they existed prior to 
repeal. If the taxpayer complied with the provisions of the regulations 
under sections 452 and 462 in computing the tax liability with the 
application of such sections, he will be regarded as having reasonably 
interpreted and applied sections 452 and 462. In this regard, it is not 
essential that the taxpayer submit with his return the detailed 
information required by such regulations in support of the deduction 
claimed under section 462, but such information shall be supplied at the 
request of the Commissioner.
    (c) Interest for periods prior to June 16, 1955. No interest shall 
be imposed with respect to any increase in tax resulting solely from the 
repeal of sections 452 and 462 for any period prior to June 16, 1955 
(the day after the date of the enactment of the Act of June 15, 1955). 
The preceding sentence does not apply to that part of any increase in 
tax which is due to the improper application of sections 452 and 462. 
The provisions of this paragraph shall not apply to interest imposed 
under section 3779 of the Internal Revenue Code of 1939. (See paragraph 
(d) of this section.)
    (d) Amounts deferred by corporations expecting carrybacks. Interest 
shall be imposed at the rate of 6 percent on so much of the amount of 
tax deferred under section 3779 of the Internal Revenue Code of 1939 as 
is not satisfied within the meaning of section 3779(i)(1), 
notwithstanding the fact that a greater amount would have been 
satisfied, had sections 452 and 462 not been repealed. Interest will be 
imposed at such rate until the amount not so satisfied is paid.