Tax Realty Consultant

The amendment to Code Sec. 6502 by the Revenue Reconciliation Act of 1990 (P.L. 101-508), which replaced the six-year limitations period with a ten-year period, extended the collection period with respect to a married couple whose tax collection waiver agreement specified an earlier cut-off date. Notice of assessment and demand for payment had been sent to the taxpayers prior to amendment of the statute, but within the former six-year limitations period. The terms of the taxpayers’ waiver did not preclude the application of the ten-year period because the waiver was not a contract. The IRS was not barred from making a collection after the date specified in the waiver.

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