I.R.C. § 6015(a) In General —
Notwithstanding section 6013(d)(3)—
I.R.C. § 6015(a)(1) —
an individual who has made a joint return may elect to seek relief under the procedures
prescribed under subsection (b); and
I.R.C. § 6015(a)(2) —
if such individual is eligible to elect the application of subsection (c), such individual
may, in addition to any election under paragraph (1), elect to limit such individual's
liability for any deficiency with respect to such joint return in the manner prescribed
under subsection (c).
Any determination under this section shall be made without regard to community property
laws.
I.R.C. § 6015(b) Procedures For Relief From Liability Applicable To All Joint Filers
I.R.C. § 6015(b)(1) In General —
Under procedures prescribed by the Secretary, if—
I.R.C. § 6015(b)(1)(A) —
a joint return has been made for a taxable year;
I.R.C. § 6015(b)(1)(B) —
on such return there is an understatement of tax attributable to erroneous items
of one individual filing the joint return;
I.R.C. § 6015(b)(1)(C) —
the other individual filing the joint return establishes that in signing the return
he or she did not know, and had no reason to know, that there was such understatement;
I.R.C. § 6015(b)(1)(D) —
taking into account all the facts and circumstances, it is inequitable to hold the
other individual liable for the deficiency in tax for such taxable year attributable
to such understatement; and
I.R.C. § 6015(b)(1)(E) —
the other individual elects (in such form as the Secretary may prescribe) the benefits
of this subsection not later than the date which is 2 years after the date the Secretary
has begun collection activities with respect to the individual making the election,
then the other individual shall be
relieved of liability for tax (including interest, penalties, and other amounts)
for such taxable year to the extent such liability is attributable to such understatement.
I.R.C. § 6015(b)(2) Apportionment Of Relief —
If an individual who, but for paragraph (1)(C), would be relieved of liability under
paragraph (1), establishes that in signing the return such individual did not know,
and had no reason to know, the extent of such understatement, then such individual
shall be relieved of liability for tax (including interest, penalties, and other
amounts) for such taxable year to the extent that such liability is attributable
to the portion of such understatement of which such individual did not know and had
no reason to know.
I.R.C. § 6015(b)(3) Understatement —
For purposes of this subsection, the term “understatement”
has the meaning given to such term by section 6662(d)(2)(A).
I.R.C. § 6015(c) Procedures To Limit Liability For Taxpayers No Longer Married Or Taxpayers Legally
Separated Or Not Living Together
I.R.C. § 6015(c)(1) In General —
Except as provided in this subsection, if an individual who has made a joint return
for any taxable year elects the application of this subsection, the individual's
liability for any deficiency which is assessed with respect to the return shall not
exceed the portion of such deficiency properly allocable to the individual under
subsection (d).
I.R.C. § 6015(c)(2) Burden Of Proof —
Except as provided in subparagraph (A)(ii) or (C) of paragraph (3), each individual
who elects the application of this subsection shall have the burden of proof with
respect to establishing the portion of any deficiency allocable to such individual.
I.R.C. § 6015(c)(3) Election
I.R.C. § 6015(c)(3)(A) Individuals Eligible To Make Election
I.R.C. § 6015(c)(3)(A)(i) In General —
An individual shall only be eligible to elect the application of this subsection
if—
I.R.C. § 6015(c)(3)(A)(i)(I) —
at the time such election is filed, such individual is no longer married to, or is
legally separated from, the individual with whom such individual filed the joint
return to which the election relates; or
I.R.C. § 6015(c)(3)(A)(i)(II) —
such individual was not a member of the same household as the individual with whom
such joint return was filed at any time during the 12-month period ending on the
date such election is filed.
I.R.C. § 6015(c)(3)(A)(ii) Certain Taxpayers Ineligible To Elect —
If the Secretary demonstrates that assets were transferred between individuals filing
a joint return as part of a fraudulent scheme by such individuals, an election under
this subsection by either individual shall be invalid (and section 6013(d)(3) shall apply to the joint return).
I.R.C. § 6015(c)(3)(B) Time For Election —
An election under this subsection for any taxable year may be made at any time after
a deficiency for such year is asserted but not later than 2 years after the date
on which the Secretary has begun collection activities with respect to the individual
making the election.
I.R.C. § 6015(c)(3)(C) Election Not Valid With Respect To Certain Deficiencies —
If the Secretary demonstrates that an individual making an election under this subsection
had actual knowledge, at the time such individual signed the return, of any item
giving rise to a deficiency
(or portion thereof) which is not allocable to such individual under subsection (d),
such election shall not apply to such deficiency
(or portion). This subparagraph shall not apply where the individual with actual
knowledge establishes that such individual signed the return under duress.
I.R.C. § 6015(c)(4) Liability Increased By Reason Of Transfers Of Property To Avoid Tax
I.R.C. § 6015(c)(4)(A) In General —
Notwithstanding any other provision of this subsection, the portion of the deficiency
for which the individual electing the application of this subsection is liable (without
regard to this paragraph) shall be increased by the value of any disqualified asset
transferred to the individual.
I.R.C. § 6015(c)(4)(B) Disqualified Asset —
For purposes of this paragraph–-
I.R.C. § 6015(c)(4)(B)(i) In General —
The term “disqualified asset” means any property or right to property transferred
to an individual making the election under this subsection with respect to a joint
return by the other individual filing such joint return if the principal purpose
of the transfer was the avoidance of tax or payment of tax.
I.R.C. § 6015(c)(4)(B)(ii) Presumption
I.R.C. § 6015(c)(4)(B)(ii)(I) In General —
For purposes of clause (i), except as provided in subclause (II), any transfer which is made after the date which is 1 year before the date on which
the first letter of proposed deficiency which allows the taxpayer an opportunity
for administrative review in the Internal Revenue Service Independent Office of Appeals
is sent shall be presumed to have as its principal purpose the avoidance of tax or
payment of tax.
I.R.C. § 6015(c)(4)(B)(ii)(II) Exceptions —
Subclause (I) shall not apply to any transfer pursuant to a decree of divorce or separate maintenance
or a written instrument incident to such a decree or
to any transfer which an individual establishes did not have as its
principal purpose the avoidance of tax or payment of tax.
I.R.C. § 6015(d) Allocation Of Deficiency —
For purposes of subsection (c)–-
I.R.C. § 6015(d)(1) In General —
The portion of any deficiency on a joint return allocated to an individual shall
be the amount which bears the same ratio to such deficiency as the net amount of
items taken into account in computing the deficiency and allocable to the individual
under paragraph
(3) bears to the net amount of all items taken into account in computing the deficiency.
I.R.C. § 6015(d)(2) Separate Treatment Of Certain Items —
If a deficiency (or portion thereof) is attributable to—
I.R.C. § 6015(d)(2)(A) —
the disallowance of a credit; or
I.R.C. § 6015(d)(2)(B) —
any tax (other than tax imposed by section 1 or 55) required to be included with the joint return;
and such item is allocated to one individual under paragraph (3), such deficiency
(or portion) shall be allocated to such individual. Any such item shall not be taken
into account under paragraph (1).
I.R.C. § 6015(d)(3) Allocation Of Items Giving Rise To The Deficiency —
For purposes of this subsection--
I.R.C. § 6015(d)(3)(A) In General —
Except as provided in paragraphs (4) and (5), any item giving rise to a deficiency
on a joint return shall be allocated to individuals filing the return in the same
manner as it would have been allocated if the individuals had filed separate returns
for the taxable year.
I.R.C. § 6015(d)(3)(B) Exception Where Other Spouse Benefits —
Under rules prescribed by the Secretary, an item otherwise allocable to an individual
under subparagraph (A) shall be allocated to the other individual filing the joint
return to the extent the item gave rise to a tax benefit on the joint return to the
other individual.
I.R.C. § 6015(d)(3)(C) Exception For Fraud —
The Secretary may provide for an allocation of any item in a manner not prescribed
by subparagraph (A) if the Secretary establishes that such allocation is appropriate
due to fraud of one or both individuals.
I.R.C. § 6015(d)(4) Limitations On Separate Returns Disregarded —
If an item of deduction or credit is disallowed in its entirety solely because a
separate return is filed, such disallowance shall be disregarded and the item shall
be computed as if a joint return had been filed and then allocated between the spouses
appropriately. A similar rule shall apply for purposes of section 86.
I.R.C. § 6015(d)(5) Child's Liability —
If the liability of a child of a taxpayer is included on a joint return, such liability
shall be disregarded in computing the separate liability of either spouse and such
liability shall be allocated appropriately between the spouses.
I.R.C. § 6015(e) Petition For Review By Tax Court
I.R.C. § 6015(e)(1) In General —
In the case of an individual against whom a deficiency has been asserted and who
elects to have subsection (b) or (c) apply, or in the case of an individual who requests
equitable relief under subsection (f)–-
I.R.C. § 6015(e)(1)(A) In General —
In addition to any other remedy provided by law, the
individual may petition the Tax Court (and the Tax Court shall have jurisdiction)
to determine the appropriate relief available to the individual under this section
if such petition is filed–-
I.R.C. § 6015(e)(1)(A)(i) —
at any time after the earlier of—-
I.R.C. § 6015(e)(1)(A)(i)(I) —
the date the Secretary mails, by certified or registered mail to the taxpayer's
last known address, notice of the Secretary's final determination of relief available
to the individual, or
I.R.C. § 6015(e)(1)(A)(i)(II) —
the date which is 6 months after the date such election is filed or request is made
with the Secretary, and
I.R.C. § 6015(e)(1)(A)(ii) —
not later than the close of the 90th day after the date described in clause (i)(I).
I.R.C. § 6015(e)(1)(B) Restrictions Applicable To Collection Of Assessment
I.R.C. § 6015(e)(1)(B)(i) In General —
Except as otherwise provided in section 6851 or 6861, no levy or proceeding in
court shall be made, begun, or prosecuted against the individual making an election
under subsection (b) or (c) or requesting equitable relief under subsection (f) for
collection of any assessment to which such election or request relates until the
close of the 90th day referred to in subparagraph (A)(ii), or, if a petition has been filed with the Tax Court under subparagraph (A), until
the decision of the Tax Court has become final. Rules similar to the rules of section
7485 shall apply with respect to the collection of such assessment.
I.R.C. § 6015(e)(1)(B)(ii) Authority To Enjoin Collection Actions —
Notwithstanding the provisions of section 7421(a), the beginning of such
levy or proceeding during the time the prohibition under clause (i)
is in force may be enjoined by a proceeding in the proper court, including the Tax
Court. The Tax Court shall have no jurisdiction under this subparagraph to enjoin
any action or proceeding unless a timely petition has been filed under subparagraph
(A) and then only in respect of the amount of the assessment to which the election
under subsection (b) or (c) relates or to which the request under subsection (f)
relates.
I.R.C. § 6015(e)(2) Suspension Of Running Of Period Of Limitations —
The running of the period of limitations in section 6502 on the collection of the assessment to which the petition under paragraph (1)(A)
relates shall
be suspended—-
I.R.C. § 6015(e)(2)(A) —
for the period during which the Secretary is prohibited by paragraph (1)(B) from
collecting by levy or a proceeding in court and for 60 days thereafter, and
I.R.C. § 6015(e)(2)(B) —
if a waiver under paragraph (5) is made, from the date the claim for relief was
filed until 60 days after the waiver is filed with the Secretary.
I.R.C. § 6015(e)(3) Limitation On Tax Court Jurisdiction —
If a suit for refund is begun by either individual filing the joint return pursuant
to section 6532—
I.R.C. § 6015(e)(3)(A) —
the Tax Court shall lose jurisdiction of the individual's action under this section
to whatever extent jurisdiction is acquired by the district court or the United
States Court of Federal Claims over the taxable years that are the subject of the
suit for refund, and
I.R.C. § 6015(e)(3)(B) —
the court acquiring jurisdiction shall have jurisdiction over the petition filed
under this subsection.
I.R.C. § 6015(e)(4) Notice To Other Spouse —
The Tax Court shall establish rules which provide the individual filing a joint
return but not making the election under subsection (b) or (c) or the request for
equitable relief under subsection
(f) with adequate notice and an opportunity to become a party to a proceeding under
either such subsection.
I.R.C. § 6015(e)(5) Waiver —
An individual who elects the application of subsection
(b) or (c) or who requests equitable relief under subsection (f)
(and who agrees with the Secretary's determination of relief) may waive in writing
at any time the restrictions in paragraph (1)(B)
with respect to collection of the outstanding assessment (whether or not a notice
of the Secretary's final determination of relief has been mailed).
I.R.C. § 6015(e)(6) Suspension Of Running Of Period For Filing Petition In Title 11 Cases —
In the case of a person who is prohibited by reason of a case under title 11, United
States Code, from filing a petition under paragraph (1)(A) with respect to a final
determination of relief under this section, the running of the period prescribed by
such paragraph for filing such a petition with respect to such final determination
shall be suspended for the period during which the person is so prohibited from filing
such a petition, and for 60 days thereafter.
I.R.C. § 6015(e)(7) Standard And Scope Of Review —
Any review of a determination made under this section shall be reviewed de novo by
the Tax Court and shall be based upon—
I.R.C. § 6015(e)(7)(A) —
the administrative record established at the time of the determination, and
I.R.C. § 6015(e)(7)(B) —
any additional newly discovered or previously unavailable evidence.
I.R.C. § 6015(f) Equitable Relief
I.R.C. § 6015(f)(1) In General —
Under procedures prescribed by the Secretary, if—
I.R.C. § 6015(f)(1)(A) —
taking into account all the facts and circumstances, it is inequitable to hold the
individual liable for any unpaid tax or any deficiency (or any portion of either),
and
I.R.C. § 6015(f)(1)(B) —
relief is not available to such individual under subsection (b) or (c),
the Secretary may relieve such individual of such liability.
I.R.C. § 6015(f)(2) Limitation —
A request for equitable relief under this subsection may be made with respect to any
portion of any liability that—
I.R.C. § 6015(f)(2)(A) —
has not been paid, provided that such request is made before the expiration of the
applicable period of limitation under section 6502, or
I.R.C. § 6015(f)(2)(B) —
has been paid, provided that such request is made during the period in which the individual
could submit a timely claim for refund or credit of such payment.
I.R.C. § 6015(g) Credits And Refunds
I.R.C. § 6015(g)(1) In General —
Except as provided in paragraphs (2) and (3), notwithstanding any other law or rule
of law (other than section 6511, 6512(b), 7121, or 7122), credit or refund shall be allowed or made to the extent attributable to the application
of this section.
I.R.C. § 6015(g)(2) Res Judicata —
In the case of any election under subsection (b) or
(c) or of any request for equitable relief under subsection (f), if a decision of
a court in any prior proceeding for the same taxable year has become final, such
decision shall be conclusive except with respect to the qualification of the individual
for relief which was not an issue in such proceeding. The exception contained in
the preceding sentence shall not apply if the court determines that the individual
participated meaningfully in such prior proceeding.
I.R.C. § 6015(g)(3) Credit And Refund Not Allowed Under Subsection (c) —
No credit or refund shall be allowed as a result of an election under subsection
(c).
I.R.C. § 6015(h) Regulations —
The Secretary shall prescribe such regulations as are necessary to carry out the
provisions of this section, including—-
I.R.C. § 6015(h)(1) —
regulations providing methods for allocation of items other than the methods under
subsection (d)(3); and
I.R.C. § 6015(h)(2) —
regulations providing the opportunity for an individual to have notice of, and an
opportunity to participate in, any administrative proceeding with respect to an election
made under subsection (b) or (c) or a request for equitable relief made under subsection
(f) by the other individual filing the joint return.
(Added by Pub. L. 105-206, title III, Sec. 3201(a), July 22, 1998, 112 Stat 685; amended by Pub. L. 105-277, title IV, Sec. 4002(c)(2), Oct. 21, 1998, 112 Stat 2681; Pub. L. 106-554, Sec. 313, Dec. 21, 2000, 114 Stat. 2763; Pub. L. 109-432, div. C, title IV, Sec. 408, Dec. 20, 2006, 120 Stat. 2922; Pub. L. 114-113, Div. Q, title IV, Sec. 424(a)(1), Dec. 18, 2015; Pub. L. 116-25, title I, Sec. 1001(b)(1)(A), 1203(a)(1), 1203(a)(2), July 1, 2019, 133 Stat. 981.)
BACKGROUND NOTES
AMENDMENTS
2019 — Subsec. (c)(4)(B)(ii)(I). Pub. L. 116-25, 1001(b)(1)(A), amended
subclause (I) by substituting “Internal Revenue Service Independent Office of Appeals”
for “Internal Revenue Service Office of Appeals”.
Subsec. (e)(7). Pub. L. 116-25, 1203(a)(1), amended subsec. (e) by adding a new par. (7).
Subsec. (f). Pub. L. 116-25, 1203(a)(2), amended subsec. (f). Before amendment it read as follows:
“(f) Equitable Relief
“Under procedures prescribed by the Secretary, if—
“(1) taking into account all the facts and circumstances, it is inequitable to hold
the individual liable for any unpaid tax or any deficiency (or any portion of either);
and
”(2) relief is not available to such individual under subsection (b) or (c),
“the Secretary may relieve such individual of such liability.”
2015 — Subsec. (e)(6). Pub. L. 114-113, Div. Q, Sec. 424(a)(1), added par. (6).
2006 - Subsec. (e)(1). Pub. L. 109-432, Sec. 408(a), amended par. (1) by inserting “, or in the case of an individual who requests equitable
relief under subsection (f)” after “who elects to have subsection (b)
or (c) apply”.
Subsec. (e)(1)(A)(i)(II). Pub. L. 109-432, Sec. 408(b)(1), amended subclause (II) by inserting “or request is made”
after “election is filed”.
Subsec. (e)(1)(B)(i). Pub. L. 109-432, Sec. 408(b)(2), amended clause (i) by inserting “or requesting equitable relief under subsection
(f)” after “making an election under subsection (b) or (c)” and by inserting “or request”
after “to which such election”.
Subsec. (e)(1)(B)(ii). Pub. L. 109-432, Sec. 408(b)(3), amended clause (ii) by inserting “or to which the request under subsection (f) relates”
after “to which the election under subsection (b) or (c) relates”.
Subsec. (e)(4). Pub. L. 109-432, Sec. 408(b)(4), amended par. (4) by inserting “or the request for equitable relief under subsection
(f)” after “the election under subsection (b) or (c)”.
Subsec. (e)(5). Pub. L. 109-432, Sec. 408(b)(5), amended par. (5) by inserting “or who requests equitable relief under subsection
(f)” after “who elects the application of subsection (b) or (c)”.
Subsec. (g)(2). Pub. L. 109-432, Sec. 408(b)(6), amended par. (2) by inserting “or of any request for equitable relief under subsection
(f)” after “any election under subsection (b) or (c)”.
Subsec. (h)(2). Pub. L. 109-432, Sec. 408(b)(7), amended par. (2) by inserting “or a request for equitable relief made under subsection
(f)” after “with respect to an election made under subsection (b) or (c)”.
2000 — Subsec. (c)(3)(B). Pub. L. 106-554, Sec. 313(a)(1), substituted “may be made at any time after a deficiency for such year is asserted
but” for “shall be made”.
Subsec. (e)(1). Pub. L. 106-554, Sec. 313(a)(3)(A), inserted “against whom a deficiency has been asserted and”
after “individual” in the matter preceding subpar. (A).
Subsec. (e)(1)(A). Pub. L. 106-554, Sec. 313(a)(3)(B), amended subpar. (A). Before amendment it read as follows:
“(A) In general. --
“The individual may petition the Tax Court
(and the Tax Court shall have jurisdiction) to determine the appropriate relief available
to the individual under this section if such petition is filed during the 90-day period
beginning on the date on which the Secretary mails by certified or registered mail
a notice to such individual of the Secretary's determination of relief available to
the individual. Notwithstanding the preceding sentence, an individual may file such
petition at any time after the date which is 6 months after the date such election
is filed with the Secretary and before the close of such 90-day period.”
Subsec. (e)(1)(B)(i). Pub. L. 106-554, Sec. 313(a)(3)(C), substituted “until the close of the 90th day referred to in subparagraph (A)(ii)”
for “until the expiration of the 90-day period described in subparagraph (A)”.
Subsec. (e)(2). Pub. L. 106-554, Sec. 313(a)(3)(D), amended par. (2). Before amendment it read as follows:
“(2) Suspension of running of period of limitations.
--
“The running of the period of limitations in section 6502 on the collection of the
assessment to which the petition under paragraph (1)(A) relates shall be suspended
for the period during which the Secretary is prohibited by paragraph (1)(B) from collecting
by levy or a proceeding in court and for 60 days thereafter.”
Subsec. (e)(3). Pub. L. 106-554, Sec. 313(a)(2)(B), amended par. (3). Before amendment it read as follows:
“(3) Applicable rules. --
“(A) Allowance of credit or refund. --
“Except as provided in subparagraph (B), notwithstanding any other law or rule of
law (other than section 6512(b), 7121, or 7122), credit or refund shall be allowed
or made to the extent attributable to the application of subsection (b) or (f).
“(B) Res judicata. --
“In the case of any election under subsection
(b) or (c), if a decision of the Tax Court in any prior proceeding for the same taxable
year has become final, such decision shall be conclusive except with respect to the
qualification of the individual for relief which was not an issue in such proceeding.
The exception contained in the preceding sentence shall not apply if the Tax Court
determines that the individual participated meaningfully in such prior proceeding.
“(C) Limitation on Tax Court jurisdiction.
--
“If a suit for refund is begun by either individual filing the joint return pursuant
to section 6532--
“(i) the Tax Court shall lose jurisdiction of the individual's action under this section
to whatever extent jurisdiction is acquired by the district court or the United States
Court of Federal Claims over the taxable years that are the subject of the suit for
refund, and
“(ii) the court acquiring jurisdiction shall have jurisdiction over the petition filed
under this subsection.”
Subsec. (e)(5). Pub. L. 106-554, Sec. 313(a)(3)(D), added par. (5).
Subsec. (g)-(h). Pub. L. 106-554, Sec. 313(a)(2)(A), redesignated subsec. (g) as subsec. (h) and added a new subsec. (g).
1998 - Subsec. (e)(3)(A). Pub. L. 105-277, Sec. 4002(c)(2), amended subpar. (A) by substituting “of subsection (b) or (f)”
for “of this section”.
EFFECTIVE DATE OF 2019 AMENDMENTS
Amendment by Pub. L. 116-25, Sec. 1001(b)(1)(A), effective on the date of the enactment of this Act [Enacted: July 1, 2019].
Amendments by Pub. L. 116-25, Sec. 1203(a)(1)-(2), applicable to petitions or requests filed or pending on or after the date of the
enactment of this Act [Enacted: July 1, 2019].
EFFECTIVE DATE OF 2015 AMENDMENT
Amendment by Pub. L. 114-113, Div. Q, Sec. 424(a)(1), effective for petitions filed under section 6015(e) of the Internal Revenue Code of 1986 after the date of the enactment of this Act [Enacted: Dec. 18, 2015].
EFFECTIVE DATE OF 2006 AMENDMENTS
Amendments by Sec. 408 of Pub. L. 109-432 effective with respect to liability for taxes arising or remaining unpaid on or after
the date of the enactment of this Act [Enacted: Dec. 20, 2006].
EFFECTIVE DATE OF 2000 AMENDMENTS
Amendments by Sec. 313(a) of Pub. L. 106-554 effective on the date of the enactment of this Act [Enactment Date: Dec. 21, 2000].
EFFECTIVE DATE OF 1998 AMENDMENTS
Amendment by Sec. 4002(c)(2) of Pub. L. 105-277 applicable as if included in the provisions of the IRS Restructuring and Reform Act
of 1998 to which it relates.
EFFECTIVE DATE
Section 3201(g) of Pub. L. 105-206 provided that:
“(1) In general. -- Except as provided in paragraph (2), the amendments made by this
section shall apply to any liability for tax arising after the date of the enactment
of this Act and any liability for tax arising on or before such date but remaining
unpaid as of such date [enacted: July 22, 1998].
“(2) 2-year period. --
The 2-year period under subsection (b)(1)(E) or (c)(3)(B) of section 6015 of the Internal Revenue Code of 1986 shall not expire before the date which is 2 years after the date of the first
collection activity after the date of the enactment of this Act [enacted: July 22,
1998].”
SEPARATE FORM FOR APPLYING FOR SPOUSAL RELIEF
Sec. 3201(c) of Pub. L. 105-206 provided that: “Not later than 180 days after the date of the enactment of this Act,
the Secretary of the Treasury shall develop a separate form with instructions for
use by taxpayers in applying for relief under section 6015(a) of the Internal Revenue Code of 1986, as added by this section.”
RIGHT TO LIMIT LIABILITY
Section 3501(b) of Pub. L. 105-206 provided that: “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.”
