Page:United States Statutes at Large Volume 112 Part 1.djvu/769

 PUBLIC LAW 105-206-JULY 22, 1998 112 STAT. 743 (1) IN GENERAL.— The amendments made by this section shall apply to deposits required to be made after the 180th day after the date of the enactment of this Act. (2) APPLICATION TO CURRENT LIABILITIES. —The amendment made by subsection (c) shall apply to deposits required to be made after December 31, 2001. SEC. 3305. SUSPENSION OF INTEREST AND CERTAIN PENALTIES WHERE SECRETARY FAILS TO CONTACT INDIVIDUAL TAX- PAYER. (a) IN GENERAL. —Section 6404 (relating to abatements) is amended by redesignating subsection (g) as subsection (h) and by inserting after subsection (f) the following new subsection: " (g) SUSPENSION OF INTEREST AND CERTAIN PENALTIES WHERE SECRETARY FAILS TO CONTACT TAXPAYER. — " (1) SUSPENSION. — "(A) IN GENERAL.— In the case of an individual who files a return of tax imposed by subtitle A for a taxable year on or before the due date for the return (including extensions), if the Secretary does not provide a notice to the taxpayer specifically stating the taxpayer's liability and the basis for the liability before the close of the 1-year period (18-month period in the case of taxable years beginning before January 1, 2004) beginning on the later of— "(i) the date on which the return is filed; or "(ii) the due date of the return without regard to extensions, the Secretary shall suspend the imposition of any interest, penalty, addition to tax, or additional amount with respect to any failure relating to the return which is computed by reference to the period of time the failure continues to exist and which is properly allocable to the suspension period. "(B) SEPARATE APPLICATION. — This paragraph shall be applied separately with respect to each item or adjustment. "(2) EXCEPTIONS.—Paragraph (1) shall not apply to— "(A) any penalty imposed by section 6651; "(B) any interest, penalty, addition to tax, or additional amount in a case involving fraud; "(C) any interest, penalty, addition to tax, or additional amount with respect to any tax liability shown on the return; or "(D) any criminal penalty. "(3) SUSPENSION PERIOD.— For purposes of this subsection, the term 'suspension period' means the period— "(A) beginning on the day after the close of the 1- year period (18-month period in the case of taxable years beginning before January 1, 2004) under paragraph (1); and "(B) ending on the date which is 21 days after the date on which notice described in paragraph (1)(A) is provided by the Secretary.". (b) EFFECTIVE DATE. —The amendments made by this section Applicability, shall apply to taxable years ending sifter the date of the enactment 26 USC 6404 of this Act. '^ °^- 59-194O-98 -25:QL3Part1

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