immunity from interest

Interest can be recovered against the United States only if express consent to such a recovery has been given by Congress. Congress has indicated in § 177(a) that its consent can take only two forms: (1) A specific provision for the payment of interest in a statute; (2) an express stipulation for the payment of interest in a contract duly entered into by agents of the United States. The consent necessary to waive the traditional immunity must be express, and it must be strictly construed.