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90-Day Letter |
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90-Day Letter |
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? Mentioned in | ? References in periodicals archive | |
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For
the nonattorney tax practitioner, being able to prepare and file a
petition is a useful skill against the tolling of a 90-day letter. The court also ruled the statute of limitations began to run when
the limited partners received their respective 90-day letters from the
IRS, since this was the date the legal obligation to pay the tax claim
began. The situation is
especially egregious with respect to the assessment of "hot
interest" under section 6621(c) of ;he Code which increases the
interest rate by two percentage points on large corporate underpayments
where the underpayment remains outstanding more than 30 days following
the issuance of either a 30-day or a 90-day letter. |
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