Natalie W. McGee - Page 6

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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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