Tax News

CCH (cch.taxgroup.com) reports:

The IRS has issued interim guidance regarding suspension of interest under Code Sec. 6404(g) as amended by the Small Business and Work Opportunity Act of 2007 (P.L. 110-28). As of November 26, 2007, the 18-month period in Code Sec. 6404(1)(A) and (3)(A), after which the IRS must suspend penalties and interest if it does not issue a notice to a taxpayer regarding tax liability, has been changed to a 36-month period.
The guidance provides two rules the IRS will follow with respect to notices issued on or after November 26, 2007, that relate to a return that was timely filed before that date. If the 18-month period has expired without notice as of November 25, 2007, penalties and interest will be suspended beginning the day after the end of the 18-month period and ending 21 days after receipt of the notice from the IRS. Otherwise, the suspension will begin on the day after the close of the 36-month period and end 21 days after the notice is provided. Examples of applications of the rules have been included.
Notice 2007-93, 2007FED ¶46,713
Other References:
Code Sec. 6404
CCH Reference - 2007FED ¶38,580.037
CCH Reference - 2007FED ¶38,580.34
Tax Research Consultant
CCH Reference - TRC IRS: 33,400
CCH Reference - TRC IRS: 33,402