SECTION 1. PURPOSE

With respect to interest accruing before October 1, 1998, this revenue procedure provides guidance, and requests public comment, regarding the application of § 6621(d) of the Internal Revenue Code. Section 6621(d) was enacted by § 3301 of the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA), Pub. L. No. 105–206, 112 Stat. 741, and was amended by § 4002(d) of the Tax and Trade Relief Extension Act of 1998, Pub. L. No. 105–277, 112 Stat. 2681. Section 6621(d) provides for a net interest rate of zero to the extent of overlapping tax underpayments and tax overpayments, and generally applies to interest for periods beginning after July 22, 1998 ( i.e., interest accruing on or after October 1, 1998). However, the net interest rate of zero in § 6621(d) also applies to interest for periods beginning before July 22, 1998 ( i.e., interest accruing before October 1, 1998), provided certain conditions are met. This revenue procedure provides guidance on, and how to comply with, those conditions.