TITLE 26. INTERNAL REVENUE CODE § 6621. Determination of rate of interest., 26 USCS § 6621
Summary
(a) General rule.
To the extent that an overpayment of tax by a corporation for any taxable period (as defined in subsection (c)(3), applied by substituting “overpayment” for “underpayment”) exceeds $10,000, subparagraph (B) shall be applied by substituting “0.5 percentage point” for “2 percentage points”.