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United States Code (Last Updated: May 24, 2014) |
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Title 26. INTERNAL REVENUE CODE |
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SubTitle F. Procedure and Administration |
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Chapter 67. INTEREST |
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SubChapter A. Interest on Underpayments |
§ 6601. Interest on underpayment, nonpayment, or extensions of time for payment, of tax
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(a) General rule If any amount of tax imposed by this title (whether required to be shown on a return, or to be paid by stamp or by some other method) is not paid on or before the last date prescribed for payment, interest on such amount at the underpayment rate established under section 6621 shall be paid for the period from such last date to the date paid.
(b) Last date prescribed for payment For purposes of this section, the last date prescribed for payment of the tax shall be determined under chapter 62 with the application of the following rules: (1) Extensions of time disregarded The last date prescribed for payment shall be determined without regard to any extension of time for payment or any installment agreement entered into under section 6159.
(2) Installment payments In the case of an election under section 6156(a) to pay the tax in installments— (A) The date prescribed for payment of each installment of the tax shown on the return shall be determined under section 6156(b),1 and (B) The last date prescribed for payment of the first installment shall be deemed the last date prescribed for payment of any portion of the tax not shown on the return. (3) Jeopardy The last date prescribed for payment shall be determined without regard to any notice and demand for payment issued, by reason of jeopardy (as provided in chapter 70), prior to the last date otherwise prescribed for such payment.
(4) Accumulated earnings tax In the case of the tax imposed by section 531 for any taxable year, the last date prescribed for payment shall be deemed to be the due date (without regard to extensions) for the return of tax imposed by subtitle A for such taxable year.
(5) Last date for payment not otherwise prescribed In the case of taxes payable by stamp and in all other cases in which the last date for payment is not otherwise prescribed, the last date for payment shall be deemed to be the date the liability for tax arises (and in no event shall be later than the date notice and demand for the tax is made by the Secretary).
(c) Suspension of interest in certain income, estate, gift, and certain excise tax cases In the case of a deficiency as defined in section 6211 (relating to income, estate, gift, and certain excise taxes), if a waiver of restrictions under section 6213(d) on the assessment of such deficiency has been filed, and if notice and demand by the Secretary for payment of such deficiency is not made within 30 days after the filing of such waiver, interest shall not be imposed on such deficiency for the period beginning immediately after such 30th day and ending with the date of notice and demand and interest shall not be imposed during such period on any interest with respect to such deficiency for any prior period. In the case of a settlement under section 6224(c) which results in the conversion of partnership items to nonpartnership items pursuant to section 6231(b)(1)(C), the preceding sentence shall apply to a computational adjustment resulting from such settlement in the same manner as if such adjustment were a deficiency and such settlement were a waiver referred to in the preceding sentence.
(d) Income tax reduced by carryback or adjustment for certain unused deductions (1) Net operating loss or capital loss carryback If the amount of any tax imposed by subtitle A is reduced by reason of a carryback of a net operating loss or net capital loss, such reduction in tax shall not affect the computation of interest under this section for the period ending with the filing date for the taxable year in which the net operating loss or net capital loss arises.
(2) Foreign tax credit carrybacks If any credit allowed for any taxable year is increased by reason of a carryback of tax paid or accrued to foreign countries or possessions of the United States, such increase shall not affect the computation of interest under this section for the period ending with the filing date for the taxable year in which such taxes were in fact paid or accrued, or, with respect to any portion of such credit carryback from a taxable year attributable to a net operating loss carryback or a capital loss carryback from a subsequent taxable year, such increase shall not affect the computation of interest under this section for the period ending with the filing date for such subsequent taxable year.
(3) Certain credit carrybacks (A) In general If any credit allowed for any taxable year is increased by reason of a credit carryback, such increase shall not affect the computation of interest under this section for the period ending with the filing date for the taxable year in which the credit carryback arises, or, with respect to any portion of a credit carryback from a taxable year attributable to a net operating loss carryback, capital loss carryback, or other credit carryback from a subsequent taxable year, such increase shall not affect the computation of interest under this section for the period ending with the filing date for such subsequent taxable year.
(B) Credit carryback defined For purposes of this paragraph, the term “credit carryback” has the meaning given such term by section 6511(d)(4)(C).
(4) Filing date For purposes of this subsection, the term “filing date” has the meaning given to such term by section 6611(f)(4)(A).
(e) Applicable rules Except as otherwise provided in this title— (1) Interest treated as tax Interest prescribed under this section on any tax shall be paid upon notice and demand, and shall be assessed, collected, and paid in the same manner as taxes. Any reference to this title (except subchapter B of chapter 63, relating to deficiency procedures) to any tax imposed by this title shall be deemed also to refer to interest imposed by this section on such tax.
(2) Interest on penalties, additional amounts, or additions to the tax (A) In general Interest shall be imposed under subsection (a) in respect of any assessable penalty, additional amount, or addition to the tax (other than an addition to tax imposed under section 6651(a)(1) or 6653 or under part II of subchapter A of chapter 68) only if such assessable penalty, additional amount, or addition to the tax is not paid within 21 calendar days from the date of notice and demand therefor (10 business days if the amount for which such notice and demand is made equals or exceeds $100,000), and in such case interest shall be imposed only for the period from the date of the notice and demand to the date of payment.
(B) Interest on certain additions to tax Interest shall be imposed under this section with respect to any addition to tax imposed by section 6651(a)(1) or 6653 or under part II of subchapter A of chapter 68 for the period which— (i) begins on the date on which the return of the tax with respect to which such addition to tax is imposed is required to be filed (including any extensions), and (ii) ends on the date of payment of such addition to tax. (3) Payments made within specified period after notice and demand If notice and demand is made for payment of any amount and if such amount is paid within 21 calendar days (10 business days if the amount for which such notice and demand is made equals or exceeds $100,000) after the date of such notice and demand, interest under this section on the amount so paid shall not be imposed for the period after the date of such notice and demand.
(f) Satisfaction by credits If any portion of a tax is satisfied by credit of an overpayment, then no interest shall be imposed under this section on the portion of the tax so satisfied for any period during which, if the credit had not been made, interest would have been allowable with respect to such overpayment. The preceding sentence shall not apply to the extent that section 6621(d) applies.
(g) Limitation on assessment and collection Interest prescribed under this section on any tax may be assessed and collected at any time during the period within which the tax to which such interest relates may be collected.
(h) Exception as to estimated tax This section shall not apply to any failure to pay any estimated tax required to be paid by section 6654 or 6655.
(i) Exception as to Federal unemployment tax This section shall not apply to any failure to make a payment of tax imposed by section 3301 for a calendar quarter or other period within a taxable year required under authority of section 6157.
(j) 2-percent rate on certain portion of estate tax extended under section 6166 (1) In general If the time for payment of an amount of tax imposed by chapter 11 is extended as provided in section 6166, then in lieu of the annual rate provided by subsection (a)— (A) interest on the 2-percent portion of such amount shall be paid at the rate of 2 percent, and (B) interest on so much of such amount as exceeds the 2-percent portion shall be paid at a rate equal to 45 percent of the annual rate provided by subsection (a). For purposes of this subsection, the amount of any deficiency which is prorated to installments payable under section 6166 shall be treated as an amount of tax payable in installments under such section. (2) 2-percent portion For purposes of this subsection, the term “2-percent portion” means the lesser of— (A) (i) the amount of the tentative tax which would be determined under the rate schedule set forth in section 2001(c) if the amount with respect to which such tentative tax is to be computed were the sum of $1,000,000 and the applicable exclusion amount in effect under section 2010(c), reduced by (ii) the applicable credit amount in effect under section 2010(c), or (B) the amount of the tax imposed by chapter 11 which is extended as provided in section 6166. (3) Inflation adjustment In the case of estates of decedents dying in a calendar year after 1998, the $1,000,000 amount contained in paragraph (2)(A) shall be increased by an amount equal to— (A) $1,000,000, multiplied by (B) the cost-of-living adjustment determined under section 1(f)(3) for such calendar year by substituting “calendar year 1997” for “calendar year 1992” in subparagraph (B) thereof. If any amount as adjusted under the preceding sentence is not a multiple of $10,000, such amount shall be rounded to the next lowest multiple of $10,000. (4) Treatment of payments If the amount of tax imposed by chapter 11 which is extended as provided in section 6166 exceeds the 2-percent portion, any payment of a portion of such amount shall, for purposes of computing interest for periods after such payment, be treated as reducing the 2-percent portion by an amount which bears the same ratio to the amount of such payment as the amount of the 2-percent portion (determined without regard to this paragraph) bears to the amount of the tax which is extended as provided in section 6166.
(k) No interest on certain adjustments For provisions prohibiting interest on certain adjustments in tax, see section 6205(a).
Prospective Amendment
For inflation adjustment of certain items in this section, see Revenue Procedures listed in a table under section 1 of this title.
References In Text
Section 6156, referred to in subsec. (b)(2), was repealed by Pub. L. 108–357, title VIII, § 867(b)(1),
Amendments
2005—Subsec. (d)(4). Pub. L. 109–135 substituted “6611(f)(4)(A)” for “6611(f)(3)(A)”.
1998—Subsec. (f). Pub. L. 105–206 inserted at end “The preceding sentence shall not apply to the extent that section 6621(d) applies.”
1997—Subsec. (c). Pub. L. 105–34, § 1242(a), inserted at end “In the case of a settlement under section 6224(c) which results in the conversion of partnership items to nonpartnership items pursuant to section 6231(b)(1)(C), the preceding sentence shall apply to a computational adjustment resulting from such settlement in the same manner as if such adjustment were a deficiency and such settlement were a waiver referred to in the preceding sentence.”
Subsec. (d)(2) to (4). Pub. L. 105–34, § 1055(a), added par. (2) and redesignated former pars. (2) and (3) as (3) and (4), respectively.
Subsec. (j). Pub. L. 105–34, § 503(c)(3), substituted “2-percent” for “4-percent” in heading.
Subsec. (j)(1). Pub. L. 105–34, § 503(a), reenacted par. heading without change and amended text generally. Prior to amendment, text read as follows: “If the time for payment of an amount of tax imposed by chapter 11 is extended as provided in section 6166, interest on the 4-percent portion of such amount shall (in lieu of the annual rate provided by subsection (a)) be paid at the rate of 4 percent. For purposes of this subsection, the amount of any deficiency which is prorated to installments payable under section 6166 shall be treated as an amount of tax payable in installments under such section.”
Subsec. (j)(2). Pub. L. 105–34, § 503(a), amended heading and text generally. Prior to amendment, text read as follows: “For purposes of this subsection, the term ‘4-percent portion’ means the lesser of—
“(A) $345,800 reduced by the amount of the credit allowable under section 2010(a); or
“(B) the amount of the tax imposed by chapter 11 which is extended as provided in section 6166.”
Subsec. (j)(3). Pub. L. 105–34, § 501(e), added par. (3). Former par. (3) redesignated (4).
Subsec. (j)(4). Pub. L. 105–34, § 503(c)(2), substituted “2-percent” for “4-percent” wherever appearing.
Pub. L. 105–34, § 501(e), redesignated par. (3) as (4).
1996—Subsec. (e)(2)(A). Pub. L. 104–168, § 303(b)(1), substituted “21 calendar days from the date of notice and demand therefor (10 business days if the amount for which such notice and demand is made equals or exceeds $100,000)” for “10 days from the date of notice and demand therefor”.
Subsec. (e)(3). Pub. L. 104–168, § 303(a), substituted “specified period” for “10 days” in heading and amended text generally. Prior to amendment, text read as follows: “If notice and demand is made for payment of any amount, and if such amount is paid within 10 days after the date of such notice and demand interest under this section on the amount so paid shall not be imposed for the period after the date of such notice and demand.”
1990—Subsec. (b)(2). Pub. L. 101–508 struck out “or 6158(a)” after “6156(a)” in introductory provisions, struck out “or 6158(a), as the case may be” after “6156(a)” in subpar. (A), and struck out at end “For purposes of subparagraph (A), section 6158(a) shall be treated as providing that the date prescribed for payment of each installment shall not be later than the date prescribed for payment of the 1985 installment.”
1989—Subsec. (e)(2). Pub. L. 101–239 substituted “section 6651(a)(1) or 6653 or under part II of subchapter A of chapter 68” for “section 6651(a)(1), 6653, 6659, 6660, or 6661” in subpars. (A) and (B).
1988—Subsec. (b)(1). Pub. L. 100–647, § 6234(b)(1), inserted “or any installment agreement entered into under section 6159” after “time for payment”.
Subsec. (b)(2). Pub. L. 100–647, § 1018(u)(42), made technical correction to directory language of Pub. L. 99–514, § 1404(c)(3), see 1986 Amendment note below.
Subsec. (e)(2)(A), (B). Pub. L. 100–647, § 1015(b)(2)(C), substituted “6653, 6659” for “6659”.
Subsec. (i). Pub. L. 100–647, § 7106(c)(5), struck out “or 3321” after “3301”.
1987—Subsec. (h). Pub. L. 100–203 substituted “section 6654 or 6655” for “section 6154 or 6654”.
1986—Subsec. (a). Pub. L. 99–514, § 1511(c)(11), substituted “the underpayment rate established under section 6621” for “an annual rate established under section 6621”.
Subsec. (b)(2). Pub. L. 99–514, § 1404(c)(3), as amended by Pub. L. 100–647, § 1018(u)(42), substituted “6156(a) or 6158(a)” for “6152(a), 6156(a), or 6158(a)” in introductory provisions and “6156(b) or 6158(a)” for “6152(b), 6156(b), or 6158(a)” in subpar. (A).
Subsec. (b)(4), (5). Pub. L. 99–514, § 1512(a), added par. (4) and redesignated former par. (4) as (5).
Subsec. (c). Pub. L. 99–514, § 1564(a), inserted “and interest shall not be imposed during such period on any interest with respect to such deficiency for any prior period”.
1984—Subsec. (d)(2)(A). Pub. L. 98–369, § 714(n)(1), made technical correction to directory language of Pub. L. 97–248, § 346(c)(2)(B). See 1982 Amendment note below.
Subsec. (d)(3), (4). Pub. L. 98–369, § 211(b)(26), redesignated par. (4) as (3) and struck out former par. (3) which had provided that if the amount of any tax imposed by subtitle A was reduced by operation of section 815(d)(5) (relating to reduction of policyholders surplus account of life insurance companies for certain unused deductions), such reduction in tax would not affect the computation of interest under this section for the period ending with the last day of the last taxable year to which the loss described in section 815(d)(5)(A) was carried under section 812(b)(2).
Subsec. (e)(2). Pub. L. 98–369, § 158(a), in amending par. (2) generally, inserted “(other than an addition to tax imposed under section 6651(a)(1), 6659, 6660, or 6661)”, and added subpar. (B).
Subsec. (h). Pub. L. 98–369, § 412(b)(7), amended subsec. (h) generally, substituting “any estimated tax required to be paid by section 6154 or 6654” for “estimated tax required by section 6153 or section 6154”.
1983—Subsec. (i). Pub. L. 98–76 inserted “or 3321” after “3301”.
1982—Subsec. (d)(1). Pub. L. 97–248, § 346(c)(2)(A), substituted “the filing date for the taxable year” for “the last day of the taxable year”.
Subsec. (d)(2)(A). Pub. L. 97–248, § 346(c)(2)(B), as amended by Pub. L. 98–369, § 346(c)(2)(B), substituted “the filing date for” for “the last day of” in two places.
Subsec. (d)(4). Pub. L. 97–248, § 346(c)(2)(C), added par. (4).
Subsec. (e). Pub. L. 97–248, § 344(b)(1), struck out par. (2) which had provided that no interest under this section was to be imposed on the interest provided by this section, and redesignated pars. (3) and (4) as (2) and (3), respectively.
1980—Subsec. (c). Pub. L. 96–223 substituted “certain excise tax cases” for “chapter 41, 42, 43, or 44 tax cases” in heading.
1978—Subsec. (d)(2). Pub. L. 95–628, § 8(c)(2)(A), substituted in heading “Certain credit carrybacks” for “Investment credit carryback”, designated existing provision as subpar. (A), and in subpar. (A) as so designated, inserted heading “In general” and in text extended the application of the provision to credit carrybacks, previously limited to investment credit carrybacks, included other credit carrybacks, and added subpar. (B).
Subsec. (d)(4), (5). Pub. L. 95–628, § 8(c)(2)(B), struck out pars. (4) and (5) which provided for work incentive program credit carrybacks and new employee credit carrybacks, respectively.
1977—Subsec. (d)(5). Pub. L. 95–30 added par. (5).
1976—Subsec. (b)(2). Pub. L. 94–452 substituted “, 6156(a), or 6158(a)” for “or 6156(a)” and “, 6156(b), or 6158(a)” for “or 6156(b)” and inserted requirement that for purposes of subparagraph (A), section 6158(a) of this title shall be treated as providing that the date prescribed for payment of each installment shall not be later than the date prescribed for payment of the 1985 installment.
Subsec. (b)(4). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”.
Subsec. (c). Pub. L. 94–455, §§ 1307(d)(2)(H), 1605(b)(10), substituted in heading “chapter 41, 42” for “chapter 42” and “43, or 44” for “or 43”.
Subsec. (d)(4). Pub. L. 94–455, § 2107(g)(2)(C), inserted “, an investment credit carryback,” after “net operating loss carryback”.
Subsec. (h). Pub. L. 94–455, § 1906(a)(34), struck out “(or section 59 of the Internal Revenue Code of 1939)”.
Subsecs. (j), (k). Pub. L. 94–455, § 2004(b), added subsec. (j) and redesignated former subsec. (j) as (k).
1975—Subsec. (a). Pub. L. 93–625, § 7(a)(2)(A), substituted “an annual rate established under section 6621” for “the rate of 6 percent per annum”.
Subsecs. (b) to (l). Pub. L. 93–625, § 7(b)(1), struck out subsec. (b) relating to extensions of time for payment of estate tax, redesignated subsecs. (c) to (i) as (b) to (h), respectively, struck out subsec. (j) relating to extensions of time for payment of tax attributable to recoveries of foreign expropriation losses, and redesignated subsecs. (k) and (l) as (i) and (j), respectively.
1974—Subsec. (d). Pub. L. 93–406 inserted reference to chapter 43 in heading, and substituted “certain excise” for “chapter 42” in text.
1971—Subsec. (e)(4). Pub. L. 92–178 added par. (4).
1969—Subsec. (d). Pub. L. 91–172, § 101(j)(49), inserted reference to chapter 42 both in subsec. heading and in text.
Subsec. (e)(1). Pub. L. 91–172, § 512(e)(3)(A), (B), substituted “loss or capital loss carryback” for “loss carryback” in heading, and “net operating loss or net capital loss” for “net operating loss” wherever it appears in text.
Subsec. (e)(2). Pub. L. 91–172, § 512(e)(3)(C), substituted “loss carryback or a capital loss carryback” for “loss carryback”.
Subsecs. (k), (l). Pub. L. 91–53 added subsec. (k) and redesignated former subsec. (k) as (l).
1967—Subsec. (e)(2). Pub. L. 90–225 inserted “, or with respect to any portion of an investment credit carryback from a taxable year attributable to a net operating loss carryback from a subsequent taxable year, such increase shall not affect the computation of interest under this section for the period ending with the last day of such subsequent taxable year,” after “the investment credit carryback arises”.
1966—Subsecs. (j), (k). Pub. L. 89–384 added subsec. (j) and redesignated former subsec. (j) as (k).
1964—Subsec. (e). Pub. L. 88–571 added par. (3) and inserted “or adjustment for certain unused deductions” in heading.
1962—Subsec. (e). Pub. L. 87–834 designated existing provisions as par. (1) and added par. (2).
1961—Subsec. (c)(2). Pub. L. 87–61 substituted “6152(a) or 6156(a)” for “6152(a)” in introductory provisions, and “6152(b) or 6156(b), as the case may be” for “6152(b)” in subpar. (A).
1958—Subsec. (b). Pub. L. 85–866, §§ 66(c), 206(e), inserted reference to section 6166, and substituted “if the time for payment of an amount of such tax is postponed or extended as provided by section 6163” for “if postponement of the payment of an amount of such tax is permitted by section 6163(a)”.
Subsecs. (g) to (j). Pub. L. 85–866, §§ 83(a)(1), 84(a), added subsecs. (g) and (h) and redesignated former subsecs. (g) and (h) as (h) and (i), respectively.
Effective Date Of Amendment
Amendment by Pub. L. 109–135 effective as if included in the provisions of the Taxpayer Relief Act of 1997, Pub. L. 105–34, to which such amendment relates, see section 409(d) of Pub. L. 109–135, set out as a note under section 961 of this title.
Pub. L. 105–206, title III, § 3301(c),
Amendment by section 501(e) of Pub. L. 105–34 applicable to estates of decedents dying, and gifts made, after
Amendment by section 503(a), (c)(2), (3) of Pub. L. 105–34 applicable to estates of decedents dying after
Pub. L. 105–34, title X, § 1055(c),
Pub. L. 105–34, title XII, § 1242(b),
Pub. L. 104–168, title III, § 303(c),
Amendment by Pub. L. 101–239 applicable to returns the due date for which (determined without regard to extensions) is after
Amendment by section 1015(b)(2)(C) of Pub. L. 100–647 applicable to returns the due date for which (determined without regard to extensions) is after
Amendment by section 1018(u)(42) of Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
Amendment by section 6234(b)(1) of Pub. L. 100–647 applicable to agreements entered into after
Amendment by section 7106(c)(5) of Pub. L. 100–647 applicable to remuneration paid after
Amendment by Pub. L. 100–203 applicable to taxable years beginning after
Amendment by section 1404(c)(3) of Pub. L. 99–514 applicable to taxable years beginning after
Amendment by section 1511(c)(11) of Pub. L. 99–514 applicable for purposes of determining interest for periods after
Pub. L. 99–514, title XV, § 1512(b),
Pub. L. 99–514, title XV, § 1564(b),
Pub. L. 98–369, div. A, title I, § 158(b),
Amendment by section 211(b)(26) of Pub. L. 98–369 applicable to taxable years beginning after
Amendment by section 412(b)(7) of Pub. L. 98–369 applicable with respect to taxable years beginning after
Amendment by section 714(n)(1) of Pub. L. 98–369 effective as if included in the provision of the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97–248, to which such amendment relates, see section 715 of Pub. L. 98–369, set out as a note under section 31 of this title.
Amendment by Pub. L. 98–76 applicable to remuneration paid after
Amendment by section 344(b)(1) of Pub. L. 97–248 applicable to interest accruing after
Amendment by section 346(c)(2) of Pub. L. 97–248 applicable to interest accruing after the 30th day after
Amendment by Pub. L. 96–223 applicable to periods after
Amendment by Pub. L. 95–628 applicable to carrybacks arising in taxable years beginning after
Amendment by Pub. L. 95–30 applicable to taxable years beginning after
Amendment by section 2004(b) of Pub. L. 94–455 applicable to estates of decedents dying after
Amendment by Pub. L. 94–452 effective
Amendment by Pub. L. 93–625 effective
Amendment by Pub. L. 93–406 applicable, except as otherwise provided in section 1017(c) through (i) of Pub. L. 93–406, for plan years beginning after
Amendment by Pub. L. 92–178 applicable to taxable years beginning after
Amendment by section 101(j)(49) of Pub. L. 91–172 effective
Amendment by section 512(e)(3) of Pub. L. 91–172 applicable with respect to net capital losses sustained in taxable years beginning after
Amendment by Pub. L. 90–225 applicable with respect to investment credit carrybacks attributable to net operating loss carrybacks from taxable years ending after
Amendment by Pub. L. 89–384 applicable with respect to amounts received after
Amendment by Pub. L. 88–571 effective, with respect to amounts added to policyholders surplus accounts, for taxable years beginning after
Amendment by Pub. L. 87–834 applicable with respect to taxable years ending after
Amendment by Pub. L. 87–61 effective
Amendment by sections 66(c) and 84(a) of Pub. L. 85–866 effective
Pub. L. 85–866, title I, § 83(d),
For effective date of amendment by section 206(e) of Pub. L. 85–866, see section 206(f) of Pub. L. 85–866, set out as a note under section 6161 of this title.
Savings
For provisions that nothing in amendment by Pub. L. 101–508 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to
Miscellaneous
Pub. L. 105–206, title III, § 3801,
Pub. L. 95–30, title III, § 305,
Pub. L. 91–172, title IX, § 946(a),
Pub. L. 85–866, title I, § 83(e),