Specificity of third-party contact notices

(a)

In general

Paragraph (1) of section 7602(c) of the Internal Revenue Code of 1986 is amended—(1)by striking and at the end of subparagraph (A),(2)by redesignating subparagraph (B) as subparagraph (C),(3)by inserting after subparagraph (A) the following new subparagraph:

(B)in any case in which the information sought to be obtained from such other persons is related to determining tax liability, has not been previously requested from the taxpayer, and could reasonably be provided by the taxpayer, identifies each specific item of information intended to be sought from such persons, and

, and

(4)by amending subparagraph (C), as redesignated by paragraph (2), to read as follows:

(C)except as otherwise provided by the Secretary, provides the taxpayer with reasonable opportunity and a period of not less than 45 days (or more, if the taxpayer requests additional time and shows reasonable cause) to respond before contact is made with such other persons.

(b)

Exception

Section 7602(c)(3) of the Internal Revenue Code of 1986 is amended—(1)by redesignating subparagraphs (A), (B), and (C) as clauses (i), (ii), and (iii), respectively, and by moving such clauses 2 ems to the right,(2)by striking Exceptions.—This subsection and inserting “Exceptions.—

(A)

In general

This subsection

, and

(3)by adding at the end the following new subparagraph:

(B)

Exception for information specificity

Subparagraph (B) of paragraph (1) shall not apply to information sought from a person other than the taxpayer if the Secretary determines that such information is necessary.

(c)

Effective date

The amendments made by this section shall apply to notices provided under section 7602(c) of the Internal Revenue Code of 1986 after the date that is 12 months after the date of the enactment of this Act.