SECTION 1. PURPOSE

This revenue procedure provides guidance with respect to the failure-to-deposit penalty provisions of section 6656 of the Internal Revenue Code (Code), as amended by section 3304(c) of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105– 206, 112 Stat. 742 (1998) (RRA). This revenue procedure describes how the Service will credit Federal tax deposits to determine whether a failure-to-deposit penalty under section 6656 should apply to deposit periods beginning after December 31, 2001. This revenue procedure applies only with respect to situations in which deposits have not been made in sufficient amounts to satisfy the cumulative deposit obligations as of at least one deposit due date.