110 STAT. 1458 PUBLIC LAW 104-168^JULY 30, 1996 "(A) DATE OF MAILING.— Rules similar to the rules of section 6213 shall apply for purposes of determining the date of the mailing referred to in paragraph (1). "(B) RELIEF. —Rules similar to the rules of section 6512(b) shall apply for purposes of this subsection. "(C) REVIEW. —An order of the Tax Court under this subsection shall be reviewable in the same manner as a decision of the Tax Court, but only with respect to the matters determined in such order.". 26 USC 6404 (b) EFFECTIVE DATE.— The amendment made by this section ^ote. shall apply to requests for abatement after the date of the enactment of this Act. SEC. 303. EXTENSION OF INTEREST-FREE PERIOD FOR PAYMENT OF TAX AFTER NOTICE AND DEMAND. (a) GENERAL RULE.— Paragraph (3) of section 6601(e) (relating to payments made within 10 days after notice and demand) is amended to read as follows: "(3) PAYMENTS MADE WITHIN SPECIFIED PERIOD AFTER NOTICE AND DEMAND. —I f notice and demand is made for pay- ment of any amount and if such amount is paid within 21 calendar days (10 business days if the amount for which such notice and demand is made equals or exceeds $100,000) after the date of such notice and demand, interest under this section on the amount so paid shall not be imposed for the period after the date of such notice and demand.". (b) CONFORMING AMENDMENTS.— (1) Subparagraph (A) of section 6601(e)(2) is amended by striking "10 days from the date of notice and demand therefor" and inserting "21 calendar days from the date of notice and demand therefor (10 business days if the amount for which such notice and demand is made equals or exceeds $100,000)". (2) Paragraph (3) of section 6651(a) is amended by striking "10 days of the date of the notice and demand therefor" and inserting "21 calendar days from the date of notice and demand therefor (10 business days if the amount for which such notice and demand is made equals or exceeds $100,000)". 26 USC 6601 (c) EFFECTIVE DATE.— The amendments made by this section note. shall apply in the case of any notice and demand given after December 31, 1996. SEC. 304. ABATEMENT OF PENALTY FOR FAILURE TO MAKE REQUIRED DEPOSITS OF PAYROLL TAXES IN CERTAIN CASES. (a) IN GENERAL.—Section 6656 (relating to failure to make deposit of taxes) is amended by adding at the end the following new subsections: "(c) EXCEPTION FOR FIRST-TIME DEPOSITORS OF EMPLOYMENT TAXES.— The Secretary may waive the penalty imposed by subsection (a) on a person's inadvertent failure to deposit any employ- ment tax if— "(1) such person meets the requirements referred to in section 7430(c)(4)(A)(iii), "(2) such failure occurs during the 1st quarter that such person was required to deposit any employment tax, and "(3) the return of such tax was filed on or before the due date. For purposes of this subsection, the term 'employment taxes' means the taxes imposed by subtitle C.
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