[Congressional Bills 107th Congress]
[From the U.S. Government Publishing Office]
[S. 189 Introduced in Senate (IS)]
107th CONGRESS
1st Session
S. 189
To amend the Internal Revenue Code of 1986 to provide tax relief for
small businesses, and for other purposes.
_______________________________________________________________________
IN THE SENATE OF THE UNITED STATES
January 25, 2001
Mr. Bond (for himself and Mr. Enzi) introduced the following bill;
which was read twice and referred to the Committee on Finance
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to provide tax relief for
small businesses, and for other purposes.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE; AMENDMENT OF 1986 CODE; TABLE OF CONTENTS.
(a) Short Title.--This Act may be cited as the ``Small Business
Works Act of 2001''.
(b) Amendment of 1986 Code.--Except as otherwise expressly
provided, whenever in this Act an amendment or repeal is expressed in
terms of an amendment to, or repeal of, a section or other provision,
the reference shall be considered to be made to a section or other
provision of the Internal Revenue Code of 1986.
(c) Table of Contents.--The table of contents is as follows:
Sec. 1. Short title; amendment of 1986 code; and table of contents.
TITLE I--TAX RELIEF
Sec. 101. Deduction for health insurance costs of self-employed
individuals increased.
Sec. 102. Alternative minimum tax.
Sec. 103. Repeal of Federal unemployment surtax.
Sec. 104. Permanent extension of research credit.
Sec. 105. Increased deduction for business meal expenses.
TITLE II--TAX SIMPLIFICATION
Sec. 201. Clarification of cash accounting rules for small business.
Sec. 202. Increase in expense treatment for small businesses.
Sec. 203. Depreciation modifications.
Sec. 204. Simplification of estimated tax rules.
Sec. 205. Exclusion from partnership filing requirements for married
couples as business co-owners.
TITLE III--TAXPAYER PROTECTIONS
Sec. 301. Taxpayer's right to have an IRS examination take place at
another site.
Sec. 302. Clarification of electronic filing.
Sec. 303. Taxpayer's election with respect to recovery of costs and
certain fees.
Sec. 304. Repeal of the failure-to-pay penalty.
Sec. 305. Repeal of interest on deficiencies.
TITLE I--TAX RELIEF
SEC. 101. DEDUCTION FOR HEALTH INSURANCE COSTS OF SELF-EMPLOYED
INDIVIDUALS INCREASED.
(a) In General.--Section 162(l)(1) (relating to special rules for
health insurance costs of self-employed individuals) is amended to read
as follows:
``(1) Allowance of deduction.--In the case of an individual
who is an employee within the meaning of section 401(c)(1),
there shall be allowed as a deduction under this section an
amount equal to the amount paid during the taxable year for
insurance which constitutes medical care for the taxpayer, the
taxpayer's spouse, and dependents.''.
(b) Clarification of Limitations on Other Coverage.--The first
sentence of section 162(l)(2)(B) is amended to read as follows:
``Paragraph (1) shall not apply to any taxpayer for any calendar month
for which the taxpayer participates in any subsidized health plan
maintained by any employer (other than an employer described in section
401(c)(4)) of the taxpayer or the spouse of the taxpayer.''.
(c) Deduction Taken Into Account for Self-Employment Tax
Purposes.--Section 162(l) is amended by striking paragraph (4) and
redesignating paragraph (5) as paragraph (4).
(d) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2000.
SEC. 102. ALTERNATIVE MINIMUM TAX.
(a) Repeal of Alternative Minimum Tax on Individuals.--
(1) In general.--Section 55(a) (relating to alternative
minimum tax) is amended by adding at the end the following new
flush sentence:
``For purposes of this title, the tentative minimum tax on any taxpayer
other than a corporation for any taxable year beginning after December
31, 2004, shall be zero.''.
(2) Reduction of tax on individuals prior to repeal.--
Section 55 is amended by adding at the end the following new
subsection:
``(f) Phaseout of Tax on Individuals.--
``(1) In general.--The tax imposed by this section on a
taxpayer other than a corporation for any taxable year
beginning after December 31, 2000, and before January 1, 2005,
shall be the applicable percentage of the tax which would be
imposed but for this subsection.
``(2) Applicable percentage.--For purposes of paragraph
(1), the applicable percentage shall be determined in
accordance with the following table:
``For taxable years beginning
The applicable
in calendar year--
percentage is--
2001................................... 80
2002................................... 60
2003................................... 40
2004................................... 20.''.
(3) Nonrefundable personal credits fully allowed against
regular tax liability.--
(A) In general.--Section 26(a) (relating to
limitation based on amount of tax) is amended to read
as follows:
``(a) Limitation Based on Amount of Tax.--The aggregate amount of
credits allowed by this subpart for the taxable year shall not exceed
the taxpayer's regular tax liability for the taxable year.''.
(B) Child credit.--Section 24(d) is amended by
striking paragraph (2) and by redesignating paragraph
(3) as paragraph (2).
(4) Effective date.--The amendments made by this subsection
shall apply to taxable years beginning after December 31, 2000.
(b) Income Averaging Not To Increase Alternative Minimum Tax
Liability.--
(1) In general.--Section 55(c) (relating to regular tax) is
amended by redesignating paragraph (2) as paragraph (3) and by
inserting after paragraph (1) the following:
``(2) Coordination with income averaging for farmers.--
Solely for purposes of this section, section 1301 (relating to
averaging of farm income) shall not apply in computing the
regular tax.''.
(2) Effective date.--The amendment made by this subsection
shall apply to taxable years beginning after December 31, 2000.
(c) Expansion of the Exemption From the Alternative Minimum Tax for
Small Corporations.--
(1) In general.--Section 55(e)(1)(A) (relating to exemption
for small corporations) is amended to read as follows:
``(A) $10,000,000 gross receipts test.--The
tentative minimum tax of a corporation shall be zero
for any taxable year if the corporation's average
annual gross receipts for all 3-taxable-year periods
ending before such taxable year does not exceed
$10,000,000. For purposes of the preceding sentence,
only taxable years beginning after December 31, 1997,
shall be taken into account.''.
(2) Gross receipts test for first 3-year period.--Section
55(e)(1)(B) is amended to read as follows:
``(B) $7,500,000 gross receipts test for first 3-
year period.--Subparagraph (A) shall be applied by
substituting `$7,500,000' for `$10,000,000' for the
first 3-taxable-year period (or portion thereof) of the
corporation which is taken into account under
subparagraph (A).''.
(3) Effective date.--The amendments made by this subsection
shall apply to taxable years beginning after December 31, 2000.
SEC. 103. REPEAL OF FEDERAL UNEMPLOYMENT SURTAX.
(a) In General.--Section 3301 (relating to rate of Federal
unemployment tax) is amended--
(1) by striking ``2007'' and inserting ``2000'', and
(2) by striking ``2008'' and inserting ``2001''.
(b) Effective Date.--The amendment made by this section shall apply
to calendar years beginning after December 31, 2000.
SEC. 104. PERMANENT EXTENSION OF RESEARCH CREDIT.
(a) In General.--Section 41 of the Internal Revenue Code of 1986
(relating to credit for increasing research activities) is amended by
striking subsection (h).
(b) Conforming Amendment.--Section 45C(b)(1) of such Code is
amended by striking subparagraph (D).
(c) Effective Date.--The amendments made by this section shall
apply to amounts paid or incurred after the date of the enactment of
this Act.
SEC. 105. INCREASED DEDUCTION FOR BUSINESS MEAL EXPENSES.
(a) In General.--Section 274(n)(1) (relating to only 50 percent of
meal and entertainment expenses allowed as deduction) is amended by
striking ``50 percent'' in the text and inserting ``the allowable
percentage''.
(b) Allowable Percentage.--Section 274(n) is amended by
redesignating paragraphs (2) and (3) as paragraphs (3) and (4),
respectively, and by inserting after paragraph (1) the following new
paragraph:
``(2) Allowable percentage.--For purposes of paragraph (1),
the allowable percentage is--
``(A) in the case of amounts for items described in
paragraph (1)(B), 50 percent, and
``(B) in the case of expenses for food or
beverages, 80 percent.''.
(c) Clarification of Special Rule for Individuals Subject to
Federal Hours of Service.--Section 274(n)(4) (relating to limited
percentages of meal and entertainment expenses allowed as deduction),
as redesignated by subsection (b), is amended to read as follows:
``(4) Special rule for individuals subject to federal hours
of service.--In the case of any expenses for food or beverages
consumed while away from home (within the meaning of section
162(a)(2)) by an individual during, or incident to, the period
of duty subject to the hours of service limitations of the
Department of Transportation, paragraph (2)(B) shall apply to
such expenses.''.
(d) Conforming Amendment.--The heading for subsection (n) of
section 274 is amended by striking ``50 Percent'' and inserting
``Limited Percentages''.
(e) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2000.
TITLE II--TAX SIMPLIFICATION
SEC. 201. CLARIFICATION OF CASH ACCOUNTING RULES FOR SMALL BUSINESS.
(a) Cash Accounting Permitted.--Section 446 (relating to general
rule for methods of accounting) is amended by adding at the end the
following new subsection:
``(g) Small Business Taxpayers Permitted to Use Cash Accounting
Method Without Limitation.--
``(1) In general.--Notwithstanding any other provision of
this title, an eligible taxpayer shall not be required to use
an accrual method of accounting for any taxable year.
``(2) Eligible taxpayer.--For purposes of this subsection--
``(A) In general.--A taxpayer is an eligible
taxpayer with respect to any taxable year if--
``(i) for all prior taxable years beginning
after December 31, 1999, the taxpayer (or any
predecessor) met the gross receipts test of
subparagraph (B), and
``(ii) the taxpayer is not a tax shelter
(as defined in section 448(d)(3)).
``(B) Gross receipts test.--A taxpayer meets the
gross receipts test of this subparagraph for any prior
taxable year if the average annual gross receipts of
the taxpayer (or any predecessor) for the 3-taxable-
year period ending with such prior taxable year does
not exceed $5,000,000. The rules of paragraphs (2) and
(3) of section 448(c) shall apply for purposes of the
preceding sentence.
``(C) Inflation adjustment.--In the case of any
taxable year beginning in a calendar year after 2001,
the dollar amount contained in subparagraph (B) shall
be increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment
determined under section 1(f)(3) for the
calendar year in which the taxable year begins,
by substituting ``calendar year 2000'' for
``calendar year 1992'' in subparagraph (B)
thereof.
If any amount as adjusted under this subparagraph is
not a multiple of $100,000, such amount shall be
rounded to the nearest multiple of $100,000.''.
(b) Clarification of Inventory Rules for Small Business.--Section
471 (relating to general rule for inventories) is amended by
redesignating subsection (c) as subsection (d) and by inserting after
subsection (b) the following new subsection:
``(c) Small Business Taxpayers Not Required To Use Inventories.--
``(1) In general.--An eligible taxpayer shall not be
required to use inventories under this section for a taxable
year.
``(2) Treatment of taxpayers not using inventories.--If an
eligible taxpayer elects not to use inventories with respect to
any property for any taxable year beginning after December 31,
2000, such property shall be treated as a material or supply
which is not incidental.
``(3) Eligible taxpayer.--For purposes of this subsection,
the term `eligible taxpayer' has the meaning given such term by
section 446(g)(2).''.
(c) Indexing of Gross Receipts Test.--Section 448(c) (relating to
$5,000,000 gross receipts test) is amended by adding at the end the
following new paragraph:
``(4) Inflation adjustment.--In the case of any taxable
year beginning in a calendar year after 2001, the dollar amount
contained in paragraph (1) shall be increased by an amount
equal to--
``(A) such dollar amount, multiplied by
``(B) the cost-of-living adjustment determined
under section 1(f)(3) for the calendar year in which
the taxable year begins, by substituting ``calendar
year 2000'' for ``calendar year 1992'' in subparagraph
(B) thereof.
If any amount as adjusted under this paragraph is not a
multiple of $100,000, such amount shall be rounded to the
nearest multiple of $100,000.''.
(d) Effective Date and Special Rules.--
(1) In general.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2000.
(2) Change in method of accounting.--In the case of any
taxpayer changing the taxpayer's method of accounting for any
taxable year under the amendments made by this section--
(A) such change shall be treated as initiated by
the taxpayer;
(B) such change shall be treated as made with the
consent of the Secretary of the Treasury; and
(C) the net amount of the adjustments required to
be taken into account by the taxpayer under section 481
of the Internal Revenue Code of 1986 shall be taken
into account over a period (not greater than 4 taxable
years) beginning with such taxable year.
SEC. 202. INCREASE IN EXPENSE TREATMENT FOR SMALL BUSINESSES.
(a) In General.--Section 179(b)(1) (relating to dollar limitation)
is amended to read as follows:
``(1) Dollar limitation.--
``(A) In general.--The aggregate cost which may be
taken into account under subsection (a) for any taxable
year shall not exceed $50,000.
``(B) Inflation adjustment.--In the case of any
taxable year beginning in a calendar year after 2001,
the dollar amount contained in subparagraph (A) shall
be increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment
determined under section 1(f)(3) for the
calendar year in which the taxable year begins,
by substituting ``calendar year 2000'' for
``calendar year 1992'' in subparagraph (B)
thereof.
If any amount as adjusted under this subparagraph is
not a multiple of $1,000, such amount shall be rounded
to the nearest multiple of $1,000.''.
(b) Expansion of Phase-Out of Limitation.--Section 179(b)(2) is
amended to read as follows:
``(2) Reduction in limitation.--
``(A) In general.--The limitation under paragraph
(1) for any taxable year shall be reduced (but not
below zero) by the amount by which the cost of section
179 property for which a deduction is allowable
(without regard to this subsection) under subsection
(a) for such taxable year exceeds $400,000.''
``(B) Inflation adjustment.--In the case of any
taxable year beginning in a calendar year after 2001,
the dollar amount contained in subparagraph (A) shall
be increased by an amount equal to--
``(i) such dollar amount, multiplied by
``(ii) the cost-of-living adjustment
determined under section 1(f)(3) for the
calendar year in which the taxable year begins,
by substituting ``calendar year 2000'' for
``calendar year 1992'' in subparagraph (B)
thereof.
If any amount as adjusted under this subparagraph is
not a multiple of $10,000, such amount shall be rounded
to the nearest multiple of $10,000.''.
(c) Time of Deduction.--The second sentence of section 179(a)
(relating to election to expense certain depreciable business assets)
is amended by inserting ``(or, if the taxpayer elects, the preceding
taxable year if the property was purchased in such preceding year)''
after ``service''.
(d) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2000.
SEC. 203. DEPRECIATION MODIFICATIONS.
(a) Computer Software Eligible for Expensing.--
(1) In general.--The heading and first sentence of section
179(d)(1) (relating to section 179 property) are amended to
read as follows:
``(1) Section 179 property.--For purposes of this section,
the term `section 179 property' means property--
``(A) which is--
``(i) tangible property to which section
168 applies, or
``(ii) computer software (as defined in
section 197(e)(3)(B)) to which section 167
applies,
``(B) which is section 1245 property (as defined in
section 1245(a)(3)), and
``(C) which is acquired by purchase for use in the
active conduct of a trade or business.''.
(2) No computer software included as section 197
intangible.--
(A) In general.--Section 197(e)(3)(A) is amended to
read as follows:
``(A) In general.--Any computer software.''.
(B) Conforming amendment.--Section 167(f)(1)(B) is
amended by striking ``; except that such term shall not
include any such software which is an amortizable
section 197 intangible''.
(b) 2-Year Applicable Recovery Period for Depreciation of Computers
and Peripheral Equipment.--
(1) In general.--Section 168(c) (relating to applicable
recovery period) is amended by adding at the end the following
flush sentence:
``In the case of 5-year property which is a computer or peripheral
equipment, the applicable recovery period shall be 2 years.''.
(2) Conforming amendments.--
(A) Section 168(g)(3)(C) (relating to alternative
depreciation system for certain property) is amended to
read as follows:
``(C) Qualified technological equipment.--
``(i) In general.--Except as provided in
clause (ii), in the case of any qualified
technological equipment, the recovery period
used for purposes of paragraph (2) shall be 5
years.
``(ii) Computers or peripheral equipment.--
In the case of any computer or peripheral
equipment, the recovery period used for
purposes of paragraph (2) shall be 2 years.''.
(B) Section 168(j)(2) (relating to depreciation of
property on Indian reservations) is amended by adding
at the end the following flush sentence:
``In the case of 5-year property which is a computer or peripheral
equipment, the applicable recovery period shall be 1 year.''.
(C) Section 467(e)(3)(A) (relating to certain
payments for the use of property or services) is
amended by adding at the end the following flush
sentence:
``In the case of 5-year property which is a computer or peripheral
equipment, the applicable recovery period shall be 2 years.''.
(c) 2-Year Depreciation Period for Computer Software.--Section
167(f)(1)(A) of the Internal Revenue Code of 1986 is amended by
striking ``36 months'' and inserting ``24 months''.
(d) Adjustments on Depreciation Limits for Luxury Automobiles.--
(1) In general.--Section 280F(a)(1)(A) (relating to
limitation on amount of depreciation for luxury automobiles) is
amended--
(A) by striking ``$2,560'' in clause (i) and
inserting ``$5,400'';
(B) by striking ``$4,100'' in clause (ii) and
inserting ``$8,500'';
(C) by striking ``$2,450'' in clause (iii) and
inserting ``$5,100''; and
(D) by striking ``$1,475'' in clause (iv) and
inserting ``$3,000''.
(2) Conforming amendment.--Section 280F(a)(1)(B)(ii)
(relating to disallowed deductions allowed for years after
recovery period) is amended by striking ``$1,475'' each place
that it appears and inserting ``$3,000''.
(e) Effective Date.--The amendments made by this section shall
apply to property placed in service after December 31, 2000.
SEC. 204. SIMPLIFICATION OF ESTIMATED TAX RULES.
(a) In General.--Section 6654(d)(1) (relating to failure by an
individual to pay estimated income tax) is amended by striking
subparagraph (C).
(b) Effective Date.--The amendment made by this section shall apply
to taxable years beginning after the date of the enactment of this Act.
SEC. 205. EXCLUSION FROM PARTNERSHIP FILING REQUIREMENTS FOR MARRIED
COUPLES AS BUSINESS CO-OWNERS.
(a) In General.--Section 6031 (relating to return of partnership
income) is amended by adding the following the new subsection:
``(f) Exception for a Married Individuals as Partnership Co-
Owners.--This section shall not apply to a partnership for any taxable
year if--
``(1) all of the capital or profits interests in the
partnership are owned by 2 individuals who are a married couple
(as determined under section 7703),
``(2) such individuals elect the application of this
subsection for such taxable year, and
``(3) such individuals file a joint return for all taxable
years of such individuals which include items from such taxable
year of the partnership.
The Secretary shall prescribe regulations for the retention of such
records as may be necessary for the administration of this chapter in
any case where an election is made under this subchapter.''.
(b) Married Couples as Business Co-Owners Permitted To File
Separate Self-Employment Tax Schedules.--Section 6017 (relating to
self-employment tax returns) is amended by adding the following new
sentence: ``The preceding sentence shall apply even if the husband and
wife elect, under section 6031(f), to be excluded from the filing
requirements of section 6031.''.
(c) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after the date of the enactment of
this Act.
TITLE III--TAXPAYER PROTECTIONS
SEC. 301. TAXPAYER'S RIGHT TO HAVE AN IRS EXAMINATION TAKE PLACE AT
ANOTHER SITE.
(a) In General.--Section 7605(a) (relating to time and place of
examination) is amended to read as follows:
``(a) Time and Place.--
``(1) In general.--The time and place of examination
pursuant to the provisions of section 6420(e)(2), 6421(g)(2),
6427(j)(2), or 7602 shall be such time and place as may be
fixed by the Secretary and as are reasonable under the
circumstances. In the case of a summons under authority of
paragraph (2) of section 7602, or under the corresponding
authority of section 6420(e)(2), 6421(g)(2), or 6427(j)(2), the
date fixed for appearance before the Secretary shall not be
less than 10 days from the date of the summons.
``(2) Limitation.--Upon request of a taxpayer, the
Secretary shall conduct any examination described in paragraph
(1) at a location other than the taxpayer's residence or place
of business, if such location is reasonably accessible to the
Secretary and the taxpayer's original books and records
pertinent to the examination are available at such location.''.
(b) Effective Date.--The amendment made by this section shall apply
to examinations occurring after the date of the enactment of this Act.
SEC. 302. CLARIFICATION OF ELECTRONIC FILING.
(a) In General.--Section 2001(a) of the Internal Revenue Service
Restructuring and Reform Act of 1998 (relating to electronic filing of
tax and information returns) is amended by--
(1) striking ``and'' at the end of paragraph (2);
(2) redesignating paragraph (3) as paragraph (4); and
(3) inserting after paragraph (2) the following new
paragraph:
``(3) electronic filing shall be a voluntary option for
taxpayers; and''.
(b) Effective Date.--The amendment made by this section shall apply
to taxable years after the date of the enactment of this Act.
SEC. 303. TAXPAYER'S ELECTION WITH RESPECT TO RECOVERY OF COSTS AND
CERTAIN FEES.
(a) In General.--
(1) Section 504(f) of title 5, United States Code, is
amended to read as follows:
``(f) A party may elect to recover costs, fees, or other expenses
under this section or under section 7430 of the Internal Revenue Code
of 1986.''.
(2) Section 2412(e) of title 28, United States Code, is
amended to read as follows:
``(e) A party may elect to recover costs, fees, or other expenses
under this section or under section 7430 of the Internal Revenue Code
of 1986.''.
(b) Coordination.--Section 7430 (relating to awarding of costs and
certain fees) is amended by adding at the end the following new
subsection:
``(h) Coordination With Equal Access to Justice Act.--This section
shall not apply to any administrative or judicial proceeding with
respect to which a taxpayer elects to recover costs, fees, or other
expenses under section 504 of title 5, United States Code, or section
2412 of title 28, United States Code.''.
(c) Effective Date.--The amendments made by this section shall
apply to proceedings initiated after the date of the enactment of this
Act.
SEC. 304. REPEAL OF THE FAILURE-TO-PAY PENALTY.
(a) In General.--Section 6651(a) is amended by striking paragraphs
(2) and (3).
(b) Conforming Amendments.--
(1) Section 6651(a) is amended--
(A) by striking ``In the case of failure--
``(1) to'' and inserting ``In the case of failure to'', and
(B) by striking the semicolon at the end of
paragraph (1) and inserting a period.
(2) Section 6651(b) is amended--
(A) by striking ``For purposes of--
``(1) subsection (a)(1)'' and inserting ``For purposes of
subsection (a)'',
(B) by striking the comma at the end of paragraph
(1) and inserting a period, and
(C) by striking paragraphs (2) and (3).
(3) Section 6651 is amended by striking subsections (c),
(d), and (e).
(4) Section 6651(f) is amended by striking ``paragraph (1)
of''.
(5) Section 6651(g) is amended to read as follows:
``(g) Treatment of Returns Prepared by Secretary Under Section
6020(b).--In the case of any return made by the Secretary under section
6020(b), such return shall be disregarded for purposes of determining
the amount of the addition under subsection (a).''.
(6) Section 6651, as amended by paragraphs (3) and (4), is
amended by redesignating subsections (f) and (g) as subsections
(c) and (d), respectively.
(7) The heading of section 6651 is amended to read as
follows:
``SEC. 6651. FAILURE TO FILE TAX RETURN.''.
(8) The table of sections for subchapter A of chapter 68 is
amended by striking the item relating to section 6651 and
inserting the following new item:
``Sec. 6651. Failure to file tax
return.''.
(9) Section 5684(c)(2) is amended by striking ``or pay
tax''.
(10) Section 6601(e)(2)(A) is amended by striking ``section
6651(a)(1)'' and inserting ``section 6651(a)''.
(c) Effective Date.--The amendments made by this section shall be
effective for failures to pay occurring after the date of the enactment
of this Act.
SEC. 305. REPEAL OF INTEREST ON PENALTIES.
(a) In General.--Section 6601(e)(2), as amended by section 304, is
amended by striking subparagraph (A) and inserting the following new
subparagraph:
``(A) In general.--No interest shall be imposed
under subsection (1) in respect of any assessable
penalty, additional amount, or addition to the tax
applied under chapter 68.''.
(b) Effective Date.--The amendment made by this section shall be
effective for assessable penalties, additional amounts, or additions to
tax imposed after the date of the enactment of this Act.
<all>