Page:United States Statutes at Large Volume 98 Part 1.djvu/1085

 PUBLIC LAW 98-369—JULY 18, 1984

98 STAT. 1037

"(A) REVOCATION OF TAX-EXEMPT STATUS.—

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"(i) 3-YEAR STATUTE OF LIMITATIONS GENERALLY.—In the case of any church tax examination with respect to the revocation of tax-exempt status under section 501(a), any tax imposed by chapter 1 (other than section 511) may be assessed, or a proceeding in court for collection of such tax may be begun without assessment, only for the 3 most recent taxable years ending before the examination notice date. "(ii) 6-YEAR STATUTE OF LIMITATIONS WHERE TAXEXEMPT STATUS REVOKED.—If an Organization is not a church exempt from tax under section 501(a) for any of the 3 taxable years described in clause (i), clause (i) shall be applied by substituting '6 most recent taxable years' for '3 most recent taxable years'. "(B) UNRELATED BUSINESS TAX.—In the case of any church tax examination with respect to the tax imposed by section 511 (relating to unrelated business income), such tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, only with respect to the 6 most recent taxable years ending before the examination notice date. "(C) EXCEPTION WHERE SHORTER STATUTE OF LIMITATIONS OTHERWISE APPLICABLE.—Subparagraphs (A) and (B) shall

not be construed to increase the period otherwise applicable under subchapter A of chapter 66 (relating to limitations on 26 USC 6501. assessment and collection). "(e) INFORMATION NOT COLLECTED IN SUBSTANTIAL COMPLIANCE WITH PROCEDURES TO STAY SUMMONS PROCEEDING.—

"(1) IN GENERAL.—If there has not been substantial compliance with— "(A) the notice requirements of subsection (a) or (b), "(B) the conference requirement described in subsection (b)(3)(A)(iii), or "(C) the approval requirement of subsection (d)(1) (if ap^ plicable), with respect to any church tax inquiry or examination, any proceeding to compel compliance with any summons with respect to such inquiry or examination shall be stayed until the court finds that all practicable steps to correct the noncompliance have been taken. The period applicable under paragraph (1) or subsection (c) shall not be suspended during the period of any stay under the preceding sentence. "(2) REMEDY TO BE EXCLUSIVE.—No suit may be maintained, and no defense may be raised in any proceeding (other than as provided in paragraph (1)), by reason of any noncompliance by the Secretary with the requirements of this section. '(f) LIMITATIONS ON ADDITIONAL INQUIRIES AND EXAMINATIONS.—

"(1) IN GENERAL.—If any church tax inquiry or examination with respect to any church is completed and does not result in— "(A) a revocation, notice of deficiency, or assessment described in subsection (d)(1), or "(B) a request by the Secretary for any significant change in the operational practices of the church (including the adequacy of accounting practices), no other church tax inquiry or examination may begin with respect to such church during the applicable 5-year period

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