§3556

Restitution Background Section 6201(a)(4)(A) provides that “[t]he Secretary shall assess and collect the amount of restitution under an order pursuant to section 3556 of title 18, United States Code, for failure to pay any tax imposed under this title in the same manner as if such amount were such tax.” The IRS may not make such an assessment until the defendant has ex- hausted all appeals and the restitution order has become final.

That section provides that the Secretary "shall assess and collect the amount ofrestitution under an order pursuant to section 3556 oftitle 18, United States Code, for failure to pay any tax imposed under this title [title 26] in the same manner as ifsuch amount were such tax." The Secretary's collection authority under section 6201(a)(4) applies only to - 11 - [*11] criminal restitution ordered after August 16, 2010.

This provision directs that "[t]he Secretary shall assess and collect the amount ofrestitution under an order pursuant to section 3556 oftitle 18, United States Code, for failure to pay any tax imposed under this title in the same manner as ifsuch amount were such tax." Sec.

That section provides that the Secretary "shall as- - 11 - sess and collect the amount ofrestitution under an order pursuant to section 3556 oftitle 18, United States Code, for failure to pay any tax imposed under this title [viz., title 26] in the same manner as ifsuch amount were such tax." The parties agree that the restitution obligation at issue arose "under an order pursuant to sec- tion 3556 oftitle 18."4 They disagree, however,

The Statutory Text The parties agree that the restitution ordered by the sentencing court is an "amount ofrestitution under an order pursuant to section 3556 oftitle 18," within the meaning ofsection 6201(a)(4).

The Statutory Text The parties agree that the restitution ordered by the sentencing court is an "amount ofrestitution under an order pursuant to section 3556 oftitle 18," within the meaning ofsection 6201(a)(4).

That section provides that the Secretary "shall as- - 11 - sess and collect the amount ofrestitution under an order pursuant to section 3556 oftitle 18, United States Code, for failure to pay any tax imposed under this title [viz., title 26] in the same manner as ifsuch amount were such tax." The parties agree that the restitution obligation at issue arose "under an order pursuant to sec- tion 3556 oftitle 18."4 They disagree, however, as to whether this restitution was ord

§§ 3556 and 3663(a) (2006), which would make each a restitution-based assessment (RBA) pursuant to section 6201(a)(4)(A). On January 8, 2024, petitioner filed her Petition. Using the Court’s simplified form petition, she checked the boxes indicating that she wished to dispute a Notice of Deficiency and a Notice of Determination of Worker Classificat