Interest
(c) Interest. Interest determined under this paragraph (c) is the interest that would be imposed under chapter 67 of the Internal Revenue Code (Code) by treating any unpaid amount of the imputed underpayment as an underpayment of tax imposed for the adjustment year (as defined in 301.6241-1(a)(1)). The interest under this paragraph (c) begins on the date prescribed for payment (as described in 301.6232-1(b)) and ends on the date payment of the imputed underpayment is made.