When will the interest suspension period under section 6404(g) end for taxpayers participate in the settlement initiative?
A-Misc.8. Section 6404(g)(3) provides that the suspension period ends 21 days after the Service provides notice to the taxpayer of the amount and the basis for the liability. Section 4(c) of Announcement 2004-46 provides that the Service will mail a draft closing agreement to the taxpayer reflecting the terms of the settlement. With the draft closing agreement, the Service will include a Revenue Agent’s Report, which will provide notice to the taxpayer of the amount and the basis for the liability. The Service will treat the mailing of the Revenue Agent’s Report as the notice required by section 6404(g)(1)(A). The suspension period will end 21 days after the date the Revenue Agent’s Report is mailed to the taxpayer.
