§6631 — Notice requirements
3 cases·3 cited
Statute Text — 26 U.S.C. §6631
The Secretary shall include with each notice to an individual taxpayer which includes an amount of interest required to be paid by such taxpayer under this title information with respect to the section of this title under which the interest is imposed and a computation of the interest.
3 Citing Cases
not agree that this fact renders the failure "harmless" and without effect on the liability. The cases that the Commissioner cites involve procedural requirements--i.e., requirements that a notice "shall include * * * a computation ofthe interest" (sec. 6631, cited in Scott v. Commissioner, T.C. Memo. 2007-91, afD, 262 F. App'x 597 (5th Cir. 2008)), that the IRS "shall furnish the taxpayer a copy ofthe record ofthe assessment" (sec. 6203, cited in Nestor v. Commissioner, 118 T.C. 162, 166-67 (20
effective date . One of the notices sent after June 30, 2001, contained telephone numbers and is treated as meeting the requirements of sections 6631 and/or 6751(a) . The remaining three notices did not meet the interest computation requirements of section 6631 . The question we must consider is whether respondent's failure to comply with the section 6631 computation of interest requirements on 3 of 10 notices has any effect on the validity or effectiveness of the 1991 assessment and/or the NFT
- 3 - Applicable Law and Administrative Procedures IRC section 6631(d) requires that the IRS notify a taxpayer at least 30 days before the day of levy.