§3461

3461(a), 112 Stat. 764, waivers executed after 1999 are invalid if not agreed to at the time the installment agreement is entered into. See sec. 6502. But because Rosenbloom' s waiver was given .in 1997, that limitation does not apply.

Under section 6502(a)(2), and RRA section 3461(c)(2), the period for collection expires on'the 90th day after Decembe r 2Congress has since enacted a new sec .

be applied, petitioner relies on a special rule (Restructuring Act rule) found in section 3461(c)(2) of the Internal Revenue Service Restructuring and Reforms Act of 1998 ; Pub.

ension covering 1982 was timely executed with respect to the 1983 assessment is supported by a preponderance of the evidence.6 6 We note, in passing, that the Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. L. 105-206, sec. 3461, 112 Stat. 764 enacted a new sec. 6502(a)(2) to provide that extensions of the 10-year statute of limitations on collection may only be made in connection with the simultaneous execution of an installment agreement. That rule is effective f

98. The Boyers also made installment payments under the 1987 installment agreement after the RFTL was filed. 3 Given that the waiver was signed before Dec. 31, 1999, the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3461(c)(2), 112 Stat. 764, provides that the expiration of the statutory period, unless suspended, would occur on Dec. 31, 2002, rather than Dec. 31, 2005. Nevertheless, because the Boyers timely requested a sec. 6330 hearing before Dec. 31, 200