SECTION 7. EXTENSION OF THE

PERIOD OF LIMITATIONS FOR ASSESSMENT

If the notice of proposed assessment is mailed or delivered before the period for assessing the trust fund recovery penalty ends, the assessment period will not end before the later of:

(1) The date that is 90 days after the Service mailed or delivered the notice of proposed assessment; or

(2) If the taxpayer has filed a timely appeal in response to the notice of proposed assessment, the date that is 30 days after the Secretary makes a final determination regarding the appeal.