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NOTES:


Effective Date of 2003 Revision

New Title XXXI sets forth procedures for actions under section 6015 (e) of this title, added by sec. 3201(a) of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105–206, 112 Stat. 734. Section 6015 (e) of this title provides for the determination by the Tax Court of the appropriate relief available to a taxpayer under that section, and is effective with respect to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before such date but remaining unpaid as of such date, except that the 2-year period for electing the benefits of that section shall not expire before the date which is 2 years after the date of the first collection activity after July 22, 1998. Similarly, the Rules of this Title XXXI generally are effective with respect to actions for determination of relief from joint and several liability on a joint return commenced with respect to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before such date but remaining unpaid as of such date; except that Rule 321 (c) is effective with respect to proceedings commenced on or after Dec. 21, 2000.
New Rule 320 is effective with respect to actions for determination of relief from joint and several liability on a joint return commenced with respect to any liability for tax arising after July 22, 1998, and any liability for tax arising on or before such date but remaining unpaid as of such date.

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