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related notice” was not required to be sent to petitioner because
the offset only merited an “accounting adjustment” notice. In
other words, respondent asserts the offset was a collection
activity under the revenue procedure but that the notice of the
offset is not a collection-related notice.
The 2-year limitation period applicable to section 6015(b)
and (c) was added to the Internal Revenue Code by the Internal
Revenue Service Restructuring and Reform Act of 1998 (RRA 1998),
sec. 3201(a), Pub. L. 105-206, 112 Stat. 734. RRA 1998 sec.
3501, 112 Stat. 770, required that the Commissioner change
collection-related notices to inform individuals subject to joint
liability of their rights to relief under section 6015. RRA 1998
sec. 3501(b), 112 Stat. 770.3 RRA 1998 sec. 3501 is part of the
3RRA 1998 sec. 3501 provides as follows:
SEC. 3501. EXPLANATION OF JOINT AND SEVERAL LIABILITY.
(a) In General.–-The Secretary of the Treasury or
the Secretary’s delegate shall, as soon as practicable,
but not later than 180 days after the date of the
enactment of this Act, establish procedures to clearly
alert married taxpayers of their joint and several
liabilities on all appropriate publications and
instructions.
(b) Right to Limit Liability.–-The procedures
under subsection (a) shall include requirements that
notice of an individual’s right to relief under section
6015 of the Internal Revenue Code of 1986 shall be
included in the statement required by section 6227 of
the Omnibus Taxpayer Bill of Rights (Internal Revenue
Service Publication No. 1) and in any collection-
related notices.
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Last modified: May 25, 2011