A quick estimator of accrued IRS underpayment interest on an additional tax assessment, calculated under §6622(a) daily compounding at §6621(a)(2) quarterly rates — with Kwong v. United States (Fed. Cl. 2025) §7508A(d) COVID-window abatement applied.
| Filing Date | Tax Year | Days | Gross | COVID-Abated | COVID + Helene | COVID Share |
|---|
IRC §6622(a) requires daily compounding of all federal tax interest. The estimator walks the timeline day by day from April 15 through June 30, 2026 — applying the applicable §6621(a)(2) quarterly rate to a running balance. A proportional allocation would overstate the COVID-window share by 15–35%.
January 20, 2020 – July 10, 2023. 1,267 days. Kwong v. United States, No. 23-267 (Fed. Cl. Nov. 25, 2025); Abdo v. Commissioner, 162 T.C. No. 7 (2024). The IRS Acting Chief Counsel conceded in Mayronne v. Commissioner (T.C. Dkt. 1984-24, Mar. 13, 2026) that COVID-window interest is not “interest as provided by law.”
September 24, 2024 – April 30, 2025. 219 net new days beyond the COVID window.
FEMA DR-4830-GA covers all 159 Georgia counties. Combined Georgia
suspension across both windows: 1,486 days.
Under §6601(b)(1), an extension of time to file under §6081 does not extend the last date prescribed for payment. Interest accrual begins on the original April 15 due date regardless of any filing extension to October 15.
Failure-to-pay penalties under §6651(a)(2); penalty interest under §6601(e)(2); any §6404(g) suspension already applied to the IRS Notice of Computational Adjustment; partial payments or credits during the accrual period.
§6621(a)(2) quarterly rates 2012–2026 sourced from IRS Revenue Rulings.
Q2 2026 rate verified at 6% per Rev. Rul. 2026-5 (IRB 2026-8). Daily rate
computed as annual ÷ 365 per IRS standard practice.