Page:United States Statutes at Large Volume 119.djvu/2627

 PUBLIC LAW 109–135—DEC. 21, 2005

119 STAT. 2609

‘‘(iii) TAXPAYERS ACTING IN GOOD FAITH.—The Secretary of the Treasury may except from the application of clause (i) any transaction in which the taxpayer has acted reasonably and in good faith. ‘‘(iv) CLOSED TRANSACTIONS.—Clause (i) shall not apply to a transaction if, as of December 14, 2005— ‘‘(I) the assessment of all Federal income taxes for the taxable year in which the tax liability to which the interest relates arose is prevented by the operation of any law or rule of law, or ‘‘(II) a closing agreement under section 7121 has been entered into with respect to the tax liability arising in connection with the transaction.’’. (2) EFFECTIVE DATE.—The amendment made by this subsection shall take effect as if included in the provisions of the American Jobs Creation Act of 2004 to which it relates. (b) TREATMENT OF AMENDED RETURNS AND OTHER SIMILAR NOTICES OF ADDITIONAL TAX OWED.— (1) IN GENERAL.—Section 6404(g)(1) (relating to suspension) is amended by adding at the end the following new sentence: ‘‘If, after the return for a taxable year is filed, the taxpayer provides to the Secretary 1 or more signed written documents showing that the taxpayer owes an additional amount of tax for the taxable year, clause (i) shall be applied by substituting the date the last of the documents was provided for the date on which the return is filed.’’. (2) EFFECTIVE DATE.—The amendment made by this subsection shall apply to documents provided on or after the date of the enactment of this Act.

26 USC 6404 note.

26 USC 6404.

26 USC 6404 note.

SEC. 304. AUTHORITY FOR UNDERCOVER OPERATIONS.

Paragraph (6) of section 7608(c) (relating to application of section) is amended by striking ‘‘January 1, 2006’’ both places is appears and inserting ‘‘January 1, 2007’’. SEC. 305. DISCLOSURES OF CERTAIN TAX RETURN INFORMATION.

(a) DISCLOSURES TO FACILITATE COMBINED EMPLOYMENT TAX REPORTING.— (1) IN GENERAL.—Subparagraph (B) of section 6103(d)(5) (relating to termination) is amended by striking ‘‘December 31, 2005’’ and inserting ‘‘December 31, 2006’’. (2) EFFECTIVE DATE.—The amendment made by paragraph (1) shall apply to disclosures after December 31, 2005. (b) DISCLOSURES RELATING TO TERRORIST ACTIVITIES.— (1) IN GENERAL.—Clause (iv) of section 6103(i)(3)(C) and subparagraph (E) of section 6103(i)(7) are each amended by striking ‘‘December 31, 2005’’ and inserting ‘‘December 31, 2006’’. (2) EFFECTIVE DATE.—The amendments made by paragraph (1) shall apply to disclosures after December 31, 2005. (c) DISCLOSURES RELATING TO STUDENT LOANS.— (1) IN GENERAL.—Subparagraph (D) of section 6103(l)(13) (relating to termination) is amended by striking ‘‘December 31, 2005’’ and inserting ‘‘December 31, 2006’’. (2) EFFECTIVE DATE.—The amendment made by paragraph (1) shall apply to requests made after December 31, 2005.

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26 USC 6103 note.

26 USC 6103 note.

26 USC 6103 note.

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