Rev. Proc. 65-20

Further consideration has been given to the position that the statutory rules regarding restriction of interest are equally applicable to an open account of the same or a different taxpayer, as stated in section 3.02(5)f of Revenue Procedure 60-17, C.B. 1960-2, 942. There are no provisions in the Internal Revenue Code of 1954 or the regulations thereunder that would make these applicable to other than the same taxpayer.

Accordingly, section 3.02(5)f of Revenue Procedure 60-17 is hereby modified to read as follows:

f. Different taxpayers .-The rules are not applicable where credit is applied to an open account of a different taxpayer. Where, with the taxpayer's consent, an overpayment is credited to another taxpayer's deficiency, the taxpayer is entitled to interest on the overpayment from the date it arose to the date the credit was allowed, and to have the interest thereon and the amount of the overpayment credited against the deficiency.