Rescission of Notice of Deficiency
IRC §6212(d)
Taxpayers can request that the Secretary rescind a notice of deficiency with their consent. Once rescinded, the notice is treated as if it never existed, allowing the taxpayer and the IRS to continue administrative resolution without being forced into Tax Court.
Eligibility
Requires mutual consent between the taxpayer and the Secretary; typically used to correct administrative errors or when the taxpayer has provided new information that resolves the deficiency.
Frequently Asked Questions
Who is eligible for the Rescission of Notice of Deficiency?
Requires mutual consent between the taxpayer and the Secretary; typically used to correct administrative errors or when the taxpayer has provided new information that resolves the deficiency.
How does the Rescission of Notice of Deficiency work?
Taxpayers can request that the Secretary rescind a notice of deficiency with their consent. Once rescinded, the notice is treated as if it never existed, allowing the taxpayer and the IRS to continue administrative resolution without being forced into Tax Court.
What law authorizes the Rescission of Notice of Deficiency?
The Rescission of Notice of Deficiency is authorized under IRC §6212(d) of the Internal Revenue Code (Title 26, United States Code).
Statutory Text — IRC §6212
Source: Internal Revenue Code, Title 26, United States Code
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Legal Sources
US Code (Official) — 26 USC §6212 → Cornell Law Institute — 26 USC §6212 → Search IRS.gov for IRC §6212(d) → Treasury Regulations (26 CFR) →Discovered by: discovery_engine_v1
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