Page:United States Statutes at Large Volume 100 Part 3.djvu/954

 100 STAT. 2762

PUBLIC LAW 99-514—OCT. 22, 1986

(b) EFFECTIVE DATE.—The amendment made by this section shall apply to notices of deficiency issued on or after January 1, 1986. SEC. 1563. AUTHORITY TO ABATE INTEREST DUE TO ERRORS OR DELAYS BY THE INTERNAL REVENUE SERVICE.

(a) IN GENERAL.—Section 6404 (relating to abatements) is amended by adding at the end thereof the following new subsection: "(e) ASSESSMENTS OF INTEREST ATTRIBUTABLE TO ERRORS AND DELAYS BY INTERNAL REVENUE SERVICE.—

"(1) IN GENERAL.—In the case of any assessment of interest on— "(A) any deficiency attributable in whole or in part to any error or delay by an officer or employee of the Internal Revenue Service (acting in his official capacity) in performing a ministerial act, or • "(B) any payment of any tax described in section 6212(a) to the extent that any delay in such payment is attributable to such an officer or employee being dilatory in performing a ministerial act, the Secretary may abate the assessment of all or any part of such interest for any period. For purposes of the preceding sentence, an error or delay shall be taken into account only if no significant aspect of such error or delay can be attributed to the taxpayer involved, and after the Internal Revenue Service has contacted the taxpayer in writing with respect to such deficiency or payment. •K^

"(2) INTEREST ABATED WITH RESPECT TO ERRONEOUS REFUND

CHECK.—The Secretary shall abate the assessment of all interest r' on any erroneous refund under section 6602 until the date demand for repayment is made, unless— "(A) the taxpayer (or a related party) has in any way caused such erroneous refund, or "(B) such erroneous refund exceeds $50,000." ' (b) EFFECTIVE DATE.—

(1) IN GENERAL.—The amendment made by subsection (a) shall apply to interest accruing with respect to deficiencies or payments for taxable years beginning after December 31, 1978. (2) STATUTE OF LIMITATIONS.—If refund or credit of any amount resulting from the application of the amendment made by subsection (a) is prevented at any time before the close of the date which is 1 year after the date of the enactment of this Act by the operation of any law or rule of law (including res ,,, judicata), refund or credit of such amount (to the extent attributable to the application of the amendment made by subsection (a)) may, nevertheless, be made or allowed if claim therefore is filed before the close of such 1-year period. SEC. 1564. SUSPENSION OF COMPOUNDING DEFICIENCY SUSPENDED.

WHERE

INTEREST

ON

(a) IN GENERAL.—Subsection (c) of section 6601 (relating to suspension of interest in certain income, estate, gift, and certain excise taxes cases) is amended by inserting before the period at the end thereof "and interest shall not be imposed during such period on any interest with respect to such deficiency for any prior period". (b) EFFECTIVE DATE.— (1) EFFECTIVE DATE.—The amendment made by subsection (a)

shall apply to interest accruing after December 31, 1982.

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