SECTION 3. SCOPE

.01 Applicability. This revenue procedure applies to a taxpayer that requests the application of the net interest rate of zero in § 6621(d) to interest for periods beginning before July 22, 1998 (i.e., interest accruing before October 1, 1998), provided:

(1) both applicable periods of limitation described in section 2.04 of this revenue procedure were open on July 22, 1998; (2) the periods of tax overpayments and underpayments for which the net interest rate of zero applies are reasonably identified and established (as described in section 4 of this revenue procedure); and

(3) the request is made not later than December 31, 1999.

.02 Inapplicability. This revenue procedure does not apply to:

(1) the application of the net interest rate of zero in § 6621(d) to interest for periods beginning after July 22, 1998 ( i.e., interest accruing on or after October 1, 1998). The Service intends to provide further guidance for those periods;

(2) an overpayment or underpayment for any period during which interest on the overpayment or underpayment was not allowable or payable by law ( e.g., the 45-day interest disallowance rule under § 6611(e)); or

(3) an offset made pursuant to §§ 6402(a) and 6601(f), regarding the crediting of an outstanding overpayment against an outstanding underpayment.