26 U.S.C. § 6622
Section 6622 · Interest compounded daily
Amended 1 time on record
Applied in 42 court decisions — leading case RJR Nabisco, Inc. v. United States (1992)
Most recently applied in 2017 T.C. Memo. 131 - Garavaglia v. Comm'r (July 2017)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
In computing the amount of any interest required to be paid under this title or sections 1961(c)(1) or 2411 of title 28, United States Code, by the Secretary or by the taxpayer, or any other amount determined by reference to such amount of interest, such interest and such amount shall be compounded daily.
Subsection (a) shall not apply for purposes of computing the amount of any addition to tax under section 6654 or 6655.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Effective Date
Section 344(c) of Pub. L. 97–248 provided that: “The amendments made by this section [enacting this section and amending section 6601 of this title] shall apply to interest accruing after December 31, 1982.”