No, Tax adjustments involving net operating loss (NOL), capital loss, and credit carrybacks are deemed effective on the due date of the loss year, in this case, 2019 (Secs. 6601(d) and 6611(f)).
Sec. 6611(e) provides that a refund relating to a carryback that is issued within 45 days of the date the carryback claim is filed will accrue no interest. If the IRS does not issue the refund within 45 days, interest will begin to accrue on the due date of the loss year.
Example: Individual Q did not fully pay her 2008 income taxes. She files a Form 1045, Application for Tentative Refund, to carry back a 2009 NOL that fully pays the unpaid 2008 tax. Interest on the 2008 balance due is computed from April 15, 2009, to April 15, 2010. Additional deficiency interest is computed on the accrued interest from April 15, 2010, until the interest is paid.
Internal Revenue Manual Part 20. Penalty and Interest
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