SECTION 5. PROCEDURES FOR

REQUESTING THE NET RATE OF ZERO

.01 Form to file . Except as provided in section 5.06 of this revenue procedure, requests for the application of the net interest rate of zero in § 6621(d) with respect to interest accruing on or after October 1, 1998, should be made on Form 843, Claim for Refund and Request for Abatement.

.02 Where to file . A Form 843 requesting the net rate of zero solely with respect to interest accruing on or after October 1, 1998, should be sent to the Internal Revenue Service Center where the taxpayer filed its most recent federal income tax return.

.03 Label . The taxpayer should label the top of the Form 843: “Request for Net Interest Rate of Zero Under Rev. Proc. 2000–26.” .04 Filing requirements for Form 843 .

(1) Line 1 should be left blank. (2) The taxpayer may, but is not required to, place a dollar amount on Line 2. (3) Line 3 should indicate the type of tax and type of return covered by the request. More than one box may be checked if more than one type of tax or return is covered by the request. In addition, any taxes imposed by the Code (or returns for those taxes) for which there is no box on Line 3 should be written in on that line.

(1) If the period of limitation for refunding underpayment interest (as described in section 4.02(1) of this revenue procedure) is open at the time a claim (as described in sections 5.01 through 5.04 of this revenue procedure) is filed or a written request (as described in section 5.06 of this revenue procedure) is made, the Service will apply the net rate of zero by decreasing underpayment interest owed by the taxpayer.

(2) If the period of limitation for refunding underpayment interest (as described in section 4.02(1) of this revenue procedure) is closed at the time a claim (as described in sections 5.01 through 5.04 of this revenue procedure) is filed or a written request (as described in section 5.06 of this revenue procedure) is made, but the period for paying additional overpayment interest (as described in section 4.02(2) of this revenue procedure) is open, the Service will apply the net rate of

(a) identify the taxable periods for which the taxpayer overpaid and underpaid its tax liability. A separate Form 843 is not required for each separate taxable period involved in the request;

(b) state when the taxpayer paid the tax if the underpayment is no longer outstanding;

(c) state when the taxpayer received a refund of tax if the overpayment is no longer outstanding;

(d) identify and establish the period(s) for which the taxpayer’s overpayment and underpayment overlapped and the overlapping amount. For this purpose, the taxpayer should provide any background material (such as copies of

(4) Line 4 should be left blank. (5) Line 5 should:

June 12, 2000 1258 2000–24 I.R.B.

examination reports, notices, or prior interest computations provided by the Service) relating to the overpayments and underpayments. The background material is needed to assist the Service in determining the period(s) for which the overpayment and underpayment overlap, and the amount of such overlap;

(e) state that, to the extent of equivalent amounts of underpayment and overpayment for the period(s) identified and established under section 5.04(5)(d) of this revenue procedure, the period(s) has (have) been used only once in a request to obtain the net interest rate of zero under § 6621(d); however, if the full amount of the overpayment or underpayment is not used in a netting calculation, the remaining portion may be used in another netting calculation; and

terest accruing before October 1, 1998, pursuant to either Rev. Proc. 99–19 or Rev. Proc. 99–43, then that taxpayer does not have to make a separate request pursuant to this revenue procedure for the portion of the overlapping period identified in that request that affects interest accruing on or after October 1, 1998. The Service will apply the net interest rate of zero to interest accruing for the entire overlapping period identified in the previously filed request at the time such request is processed. Similarly, if a taxpayer anticipates that a request will be filed pursuant to Rev. Proc. 99–43, then the taxpayer may request the net interest rate of zero for the entire overlapping period and will not be required to make a separate request under this revenue procedure for the portion of the overlapping period that affects interest accruing on or after October 1, 1998. The Service will apply the net interest rate of zero to interest accruing for the entire overlapping period identified in the request at the time such request is processed.