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That's the cost of having access to $3,300 of IRS's money for several months. Not fair, I agree, but presumably they had the benefit of the funds in their possession and were using the funds for about six months. $88 isn't an unreasonable amount for using $3,300 of someone else's money for six months. I know--clients don't think too much of that line of reasoning. Nor would I, in their shoes.