Any portion of an internal revenue tax (or any interest, assessable penalty, additional amount, or addition to tax) which has been erroneously refunded, and which is recoverable by a civil action pursuant to 26 U.S.C. 7405 , shall bear interest at the underpayment rate referred to in § 70.93 of this part.
27 C.F.R. §70.91
26 U.S.C. 6602