SECTION 3. SCOPE

.01 Applicability. This revenue procedure applies to 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).

2000–24 I.R.B. 1257 June 12, 2000

.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 before July 22, 1998 ( i.e., interest accruing before October 1, 1998) (see Rev. Proc. 99–43 for guidance regarding interest accruing before October 1, 1998); (2) interest accruing on or after January 1, 1999, for taxpayers other than corporations (the interest rate on underpayments and overpayments is equal for such taxpayers on or after January 1, 1999);

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

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