context: Washington contends that interest cannot compensate for actual pecuniary loss because this court has held that interest is an integral part of the tax itself.
citation_a.signal: see
citation_a.identifier: 886 F.2d 1101, 1108
citation_a.parenthetical: "Penalties, unlike interest, are not normally considered integral to the tax debt itself_"
citation_a.sentence: See In re Mark Anthony Const., Inc., 886 F.2d 1101, 1108 (9th Cir.1989) (“Penalties, unlike interest, are not normally considered integral to the tax debt itself_”)• This contention is meritless. The Mark Anthony court specifically held “that interest accruing on taxes due after the filing of a bankruptcy petition is to be treated as an administrative expense of the bankruptcy estate, and consequently afforded first priority status [under 11 U.S.C. § 503(b)].” Id. at 1102. Interest clearly compensates for the taxing agency’s losses relating to the “time value” of money, and nothing in Mark Anthony contradicts this notion.
citation_b.signal: see also
citation_b.identifier: 76 B.R. 176, 178
citation_b.parenthetical: "A penalty assessment is separate and distinct from the imposition of interest. Interest is assessed by the IRS to compensate for lost monetary value' while a penalty is ordinarily charged for failure to act by a certain deadline."
citation_b.sentence: See also In re Brinegar, 76 B.R. 176, 178 (Bankr.D.Col.1987) (“A penalty assessment is separate and distinct from the imposition of interest. Interest is assessed by the IRS to compensate for lost monetary value' while a penalty is ordinarily charged for failure to act by a certain deadline.”).