Page:United States Statutes at Large Volume 98 Part 1.djvu/744

 98 STAT. 696

PUBLIC LAW 98-369—JULY 18, 1984 SEC. 158. INTEREST ON CERTAIN ADDITIONS TO TAX.

26 USC 6601.

(a) IN GENERAL,—Paragraph (2) of section 6601(e) (relating to interest on penalties and additions to tax) is amended to read as follows: "(2) INTEREST O N PENALTIES, ADDITIONAL AMOUNTS, OR ADDITIONS TO THE TAX.—

Ante, p. 694.

"(A) IN GENERAL.—Interest shall be imposed under subsection (a) in respect of any assessable penalty, additional amount, or addition to the tax (other than an addition to tax imposed under section 6651(a)(1), 6659, 6660, or 6661) only if such assessable penalty, additional amount, or addition to the tax is not paid within 10 days from the date of notice and demand therefor, and in such case interest shall be imposed only for the period from the date of the notice and demand to the date of payment. "(B) INTEREST ON CERTAIN ADDITIONS TO TAX.—Interest

26 USC 6601 note.

shall be imposed under this section with respect to any addition to tax imposed by section 6651(a)(1), 6659, 6660, or 6661 for the period which— "(i) begins on the date on which the return of the tax

with respect to which such addition to tax is imposed is required to be filed (including any extensions), and "(ii) ends on the date of payment of such addition to tax." (b) EFFECTIVE DATE.—The amendment made by this section shall apply to interest accrued after the date of the enactment of this Act, except with respect to additions to tax for which notice and demand is made before such date. SEC. 159. PENALTY FOR FRAUDULENT WITHHOLDING EXEMPTION CERTIFICATE OR FAILURE TO SUPPLY INFORMATION.

26 USC 7205.

26 USC 7205 note.

(a) IN GENERAL.—Section 7205 (relating to penalty for fraudulent withholding exemption certificate) is amended— (1) by striking out "in lieu o f each place it appears and inserting in lieu thereof "in addition to", and (2) by striking out "(except the penalty provided by section 6682)" each place it appears. (b) EFFECTIVE DATE.—The amendments made by this section shall apply to actions and failures to act occurring after the date of the enactment of this Act. SEC. 160. APPLICATION OF PENALTY FOR FRIVOLOUS PROCEEDINGS TO PENDING TAX COURT PROCEEDINGS.

26 USC 7430 note.

Ante, p. 494. 26 USC 446.

Paragraph (2) of section 292(e) of the Tax Equity and Fiscal Responsibility Act of 1982 is amended to read as follows: "(2) PENALTY.—The amendments made by subsections (b) and (d)(2) shall apply to any action or proceeding in the United States Tax Court which— "(A) is commenced after December 31, 1982, or "(B) is pending in the United States Tax Court on the day which is 120 days after the date of the enactment of the Tax Reform Act of 1984." SEC. 161. FAILURE TO REQUEST CHANGE OF METHOD OF ACCOUNTING. (a) IN GENERAL.—Section 446 (relating to general rule for methods of accounting) is amended by adding at the end thereof the following new subsection:

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