SECTION 14. PROCEDURE &
Internal Revenue Bulletin 2005-20 · 2026-10-03 edition · updated 2026-10-04 · United States
ADMINISTRATION ISSUES
.01 Bankruptcy and Collection
| Statute or Regulation | Act Postponed | |
|---|---|---|
| 1. | Treas. Reg. § 301.6036–1(a)(2) and (3) |
A court-appointed receiver or fiduciary in a non-bankruptcy receivership, a fiduciary in aid of foreclosure who takes possession of substantially all of the debtor’s assets, or an assignee for benefit of creditors, must give written notice within ten days of his appointment to the IRS as to where the debtor will file his tax return. |
| 2. | Sec. 6320(a)(3)(B) and (c) and Treas. Reg. § 301.6320–1(b), (c) and (f) |
A taxpayer has 30 days after receiving a notice of a lien to request a Collection Due Process (CDP) administrative hearing. After a determination at the CDP hearing, the taxpayer may appeal this determination within 30 days to the United States Tax Court or a United States district court. |
| 3. | Sec. 6330(a)(3)(B) and (d)(1) and Treas. Reg. § 301.6330–1(b), (c) and (f) |
The taxpayer must request a Collections Due Process (CDP) administrative hearing within 30 days after the IRS sends notice of a proposed levy. After a determination at the CDP hearing, the taxpayer may appeal this determination within 30 days to the United States Tax Court or a United States district court. |
| 4. | Sec. 6331(k)(1) and Treas. Reg. § 301.7122–1(g)(2) |
If a taxpayer submits a good-faith revision of a rejected offer in compromise within 30 days after the rejection, the Service will not levy to collect the liability before deciding whether to accept the revised offer. |
| 5. | Sec. 6331(k)(2) and Treas. Reg. § 301.6331–4(a)(1) |
If, within 30 days following the rejection or termination of an installment agreement, the taxpayer files an appeal with the IRS Office of Appeals, no levy may be made while the rejection or termination is being considered by Appeals. |
| 6. | Sec. 7122(d)(2) and Treas. Reg. § 301.7122–1(f)(5)(i) |
A taxpayer must request administrative review of a rejected offer in compromise within 30 days after the date on the letter of rejection. |
May 16, 2005 1070 2005–20 I.R.B.
.02 Information Returns
| Statute or Regulation | Act Postponed | |
|---|---|---|
| 1. | Sec. 6050I | Any person engaged in a trade or business receiving more than $10,000 cash in one transaction (or 2 or more related transactions) must file an information return, Form 8300,_ Report of Cash Payments over $10,000 Received in a Trade or Business_, by the 15th day after the date the cash was received. Additionally, a statement must be provided to the person with respect to whom the information is required to be furnished by Jan. 31st of the year following. |
| 2. | Sec. 6050L | Returns relating to certain dispositions of donated property, Forms 8282,_ Donee_ Information Return, must be filed within 125 days of the disposition. |
.03 Miscellaneous
| Statute or Regulation | Act Postponed | |
|---|---|---|
| 1. | Sec. 1314(b) | A taxpayer may file a claim for refund or credit of tax based upon the mitigation provisions of sections 1311 through 1314 if, as of the date a determination (as defined in section 1313(a)) is made, one year remains on the period for filing a claim for refund. |
| 2. | Sec. 6015 | A requesting spouse must request relief under section 6015 within 2 years of the first collection activity against the requesting spouse. |
| 3. | Sec. 6411 | Taxpayers applying for a tentative carryback adjustment of the tax for the prior taxable year must file Form 1139,_ Corporation Application for Tentative Refund, (for corporations) or Form 1045, Application for Tentative Refund,_ (for entities other than corporations) within 12 months after the end of such taxable year that generates such net operating loss, net capital loss, or unused business credit from which the carryback results. |
| 4. | Sec. 6656(e)(2) | A taxpayer who is required to deposit taxes and fails to do so is subject to a penalty under section 6656. Under section 6656(e)(2), the taxpayer may, within 90 days of the date of the penalty notice, designate to which deposit period within a specified tax period the deposits should be applied. |
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