IRS Issues Rules for Suspension of Penalties, Interest for Section 6404(g)

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IRS issues final regulations (T.D. 9545) explaining the general rules for suspension of interest, penalties, additions to tax, or additional amounts under Section 6404(g). The rules incorporate a special rule from Notice 2007-93 about the effective date of changes to Section 6404(g) made by the Small Business and Work Opportunity Act of 2007, which extended the period within which IRS, without suspension of penalties, can contact a taxpayer regarding possible adjustments to the taxpayer's liability from 18 months to 36 months for notices provided after Nov. 25, 2007. The rules apply to notices from IRS on or after Nov. 26, 2007, that relate to individual federal income tax returns that were timely filed before that date.