Withholding of tax refunds: Commissioner may retain refunds or demand security when proceedings risk revenue recovery. Where a person is entitled to a refund but a proceeding or audit is pending and the Commissioner believes payment would adversely affect revenue or impede recovery, the Commissioner may, for reasons recorded in writing, require security equal to the refund or withhold the refund until conclusion of the proceeding; if a later proceeding establishes entitlement, the person shall be entitled to interest as provided under the Act.