SECTION 2. BACKGROUND

Internal Revenue Bulletin 1998-43 · 2026-10-03 edition · updated 2026-10-04 · United States

.01 Section 6212(a) provides that if the Secretary determines that there is a deficiency in respect of any tax imposed by subtitle A of title 26 (relating to income taxes), subtitle B (relating to estate, gift, and generation-skipping taxes), or chapters 41, 42, 43, or 44 (relating to certain excise taxes), the Secretary is authorized to send a notice of the deficiency to the taxpayer by certified mail or registered mail.

the notice is rescinded, the statute of limitations again begins to run and (in this example) six months remains

[sic] until the statute expires. H.R. Rep. No. 795, 100th Cong., 2d Sess. 364 (1988).

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Internal Revenue Bulletin 1998-43

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