Interest on Underpayment, Nonpayment, or Extensions of Time for Payment of Tax (Interest v. No Interest Imposed)

ID: CCA_2010121415030837 Number: 201103048
Release Date: 1/21/2011
Office: ---
UILC: 6601.00-00
From: ---
Sent: Tuesday, December 14, 2010 3:03:21 PM
To: ---
Cc: ---
Subject: RE: IRM 20.2.5 - 906 agreements, 6601(c) suspension
Section 6601(c) provides that a TEFRA settlement has the same effect as a section 6213(d) waiver. So both a TEFRA partnership item Form 906 closing agreement and TEFRA Forms 870-P will generally be treated the same as a section 6213(d) waiver.