SECTION 6. REQUEST FOR

COMMENTS

.01 For the application of the net inter

est rate of zero in computing interest accruing before October 1, 1998, taxpayers must reasonably identify and establish periods of overlapping overpayments and underpayments for which the net interest rate of zero applies, and not later than December 31, 1999, request that § 6621(d) be applied. The Treasury Department and the Service recognize that by December 31, 1999, some taxpayers may not be able to provide a final computation of how the net interest rate of zero applies to interest accruing before October 1, 1998. For example, a taxpayer may not be able to provide this final computation by December 31, 1999, because the Service’s examination of the taxable years involved has not been completed or commenced.

.02 Written comments are requested regarding the level of specificity necessary to reasonably identify and establish on or before December 31, 1999, the period(s) for which an equivalent amount of overpayment and underpayment of tax overlap when the taxpayer cannot provide by December 31, 1999, a final computation of how the net interest rate of zero applies to interest accruing before October 1, 1998. Comments should be submitted by May 14, 1999, either to: Internal Revenue Service P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Attn: CC:DOM:CORP:R (IT&A, Branch 1) Room 5228 or electronically via: http://www.irs.ustreas.gov/prod/tax_regs/ comments.html (the Service’s internet site).