Bank of America in Dispute with IRS over $200M in Interest Fees

Earlier this month, Bank of America filed a federal lawsuit against the United States Government claiming it’s owed nearly $200 million in interest previously paid to the Internal Revenue Service (IRS).

The suit, which was filed in Bank of America’s home state of North Carolina, focuses on interest that the bank claims it was charged on federal income tax underpayments and overpayments. According to the bank, the complaint covers payments made through several predecessors and acquired companies dating back to the 1980s.

In the claim, Bank of America has argued that the IRS erred during the process where it calculated interest on underpayments and overpayments. While the bank has acknowledged that it received designated funds for Merrill Lynch, the lawsuit alleges that the IRS has disallowed other claims.

Bank of America also indicated that it previously filed a related suit in federal claims court. In that suit, Bank of America is seeking approximately $15 million.

Understanding IRS Disputes


In the United States, the Internal Revenue Code (IRC) serves as the primary statutory basis for federal tax law. Enforced by the IRS, this code details the laws that individuals and businesses must follow when paying a portion of their income to the federal government.

While the tax code can be incredibly complex for the average taxpayer, it is important to grasp your fundamental obligations, as either an individual taxpayer or corporate entity. Failure to do so could lead to violations of the IRC.

When there is a violation of the tax code, the IRS may contact you with a dispute. Disputes can stem from a number of areas, including:

  • Tax penalties
  • Unfiled tax returns
  • Back taxes
  • Employment taxes

Whether you are dealing with unpaid taxes or are at risk of significant tax penalties, it is important that you seek the guidance of an experienced tax attorney.

Only a professional specializing in this legal arena can work with you to identify your goals and develop a strategy to resolve IRS issues.

Depending on the situation, resolving your IRS issues may require:

  • Penalty abatement
  • Installment agreement
  • Offer in Compromise
  • Filing a claim in U.S. Tax Court
  • Filing a claim in U.S. Federal Court

Tax Attorneys in Texas


If you or someone you know are currently dealing with a tax dispute or other IRS-related issues, the legal team at the Scammahorn Law Firm, P.C. specialize in a wide variety of tax-related matters, including disputes that arise with the IRS. Our firm is proud to serve as a leading resource for these types of cases, and our team of subject matter specialists can provide the sound legal counsel you need to bring your claim through to a swift resolution.

To get started, we invite you to call our office today (903) 595-1000 to schedule a preliminary consultation to assess your case.