[Federal Register Volume 66, Number 9 (Friday, January 12, 2001)]
[Rules and Regulations]
[Pages 2817-2821]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 01-623]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[TD 8939]
RIN 1545-AX13


Definition of Last Known Address

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations.

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SUMMARY: This document contains final regulations defining last known 
address in relation to the mailing of notices of deficiency and other 
notices, statements, and documents sent to a taxpayer's last known 
address. The final regulations affect taxpayers who receive notices of 
deficiency and other notices, statements, and documents sent to 
taxpayers' last known addresses.

DATES: Effective date: These regulations are effective January 12, 
2001.
    Applicability date: For dates of applicability, see Sec. 301.6212-
2(d).

FOR FURTHER INFORMATION CONTACT: Charles A. Hall, (202) 622-4940 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION:

Background

    This document contains amendments to the Regulations on Procedure 
and Administration (26 CFR part 301) under section 6212(b) relating to 
the sufficiency of a notice of deficiency if it is mailed to the last 
known address of a taxpayer. This document also contains amendments to 
the Income Tax Regulations (26 CFR part 1) and the Regulations on 
Procedure and Administration (26 CFR part 301) to provide cross-
references to the last known address rules under section 6212(b) in 
order to apply those rules to other notices, statements, and documents 
required to be sent to the last known address of a taxpayer.
    A notice of proposed rulemaking (REG-104939-99) was published in 
the Federal Register (64 FR 63768) on November 22, 1999. No public 
hearing was requested or held. Three written comments were received. 
After consideration of the comments, the proposed regulations are 
adopted as modified by this Treasury decision. The comments are 
discussed below.

Explanation of Revisions

    Under the proposed regulations, the IRS would have accessed the 
United States Postal Service (USPS) National Change of Address database 
(NCOA database) annually to update all taxpayer address records 
maintained in the IRS's automated masterfile for purposes of updating 
the IRS's mailing list. The IRS's mailing list contains the last known 
address for each taxpayer. In addition, prior to mailing correspondence 
to any particular taxpayer from an IRS Service Center, the IRS would 
have accessed the NCOA database to update the taxpayer's last known 
address. Employees mailing correspondence from one of the district 
offices would have accessed an updated address by virtue of the annual 
update of the entire masterfile. Except in the case of certain joint 
filers, the annual update was scheduled to occur in May 2000, November 
2000, and every November thereafter. The update based on correspondence 
mailed from an IRS Service Center was scheduled to begin May 2000. All 
steps necessary to implement the proposed regulations were not 
completed by May 2000. Therefore, the IRS delayed use of the NCOA 
database to update a taxpayer's last known address. See Announcement 
2000-49 (2000-19 I.R.B. 998 (May 8, 2000)).
    The procedures for updating taxpayer address records maintained in 
the IRS's automated masterfile are modified by these regulations. 
Implementing the proposed procedures for updating a taxpayer's last 
known address upon the mailing of correspondence from a Service Center 
required complicated programming that resulted in the delay in 
finalizing the proposed regulations. In addition, one commentator on 
the proposed regulations noted that the difference in treatment for 
Service Center mailings and district office mailings might cause 
confusion for taxpayers. The IRS, in conjunction with the USPS, has 
developed an improved system for updating taxpayer addresses that is 
intended to be easier to implement and operate and minimize confusion.
    To gain access to the NCOA database, the IRS has become a limited 
licensee of the NCOA database. The NCOA database is a computerized 
record of changes of address maintained by the USPS. This database 
retains address changes for a thirty-six month period. As a limited 
licensee, the IRS will receive from the USPS a copy of the entire 
thirty-six month NCOA database. The IRS's copy of the NCOA database 
will be retained at the Martinsburg Computing Center (MCC) in 
Martinsburg, West Virginia. Additionally, the IRS will receive weekly 
updates to the NCOA database. The updates will contain the most recent 
changes of address submitted to the USPS. The IRS will update its copy 
of the full NCOA database with the most recent changes of address in 
the weekly update.
    Beginning in January 2001, the IRS will access the NCOA database to 
update taxpayer address records maintained in the IRS's automated 
masterfile for purposes of updating the IRS's mailing list. The IRS 
plans to undertake two different procedures in order to assure the most 
comprehensive update of taxpayer addresses.
    First, the IRS will compare taxpayer addresses in IRS's records to 
the most recent changes of address contained in the weekly updates to 
the NCOA

[[Page 2818]]

database received from the USPS. To accomplish this, the IRS will use 
the USPS's FASTCheck system. The FASTCheck System works by comparing 
key elements of existing taxpayer address information maintained in IRS 
records to an extract of the same elements from the weekly updates to 
the NCOA. The key address elements used by IRS to detect possible 
matches include primary house number, secondary number, secondary 
designator, and nine digit zip code. If there is a match between the 
key address elements from IRS records and the key address elements from 
the weekly update to the NCOA database, the IRS will then compare the 
taxpayer's complete address information in IRS records to the full NCOA 
database to determine if there is a change of address for a taxpayer. 
If the taxpayer's name and last known address in IRS records match the 
taxpayer's name and old mailing address contained in the NCOA database, 
the new address in the NCOA database is the taxpayer's last known 
address, unless the IRS is given clear and concise notification of a 
different address. A match will only be made if the taxpayer's name in 
IRS records is the same, within certain tolerances, as is found in the 
NCOA database. There may be a delay of up to two to three weeks from 
the date a taxpayer notifies the USPS that his or her change of address 
is effective and the time the new address is posted to the IRS's 
automated masterfile.
    In addition, the IRS plans to annually compare all taxpayer address 
records maintained in the IRS's automated masterfile with the full 
thirty-six month NCOA database for purposes of updating the IRS's 
mailing list. The IRS will begin comparing all taxpayer address records 
with the full NCOA database for the first time in January 2001. If the 
taxpayer's name and last known address in IRS records match the 
taxpayer's name and old mailing address contained in the NCOA database, 
the new address in the NCOA database is the taxpayer's last known 
address, unless the IRS is given clear and concise notification of a 
different address. As with the weekly updates, the names must be the 
same, within certain tolerances, in both the IRS's records and the NCOA 
database. Matching all taxpayer address records to the full NCOA 
database will take several months. The next annual update will be 
completed by September 30, 2002, and every September 30th thereafter if 
the IRS determines that subsequent annual updates are necessary in 
addition to the weekly updates.
    For taxpayers who file joint income tax returns under section 6013, 
the IRS's automated masterfile is currently only able to retain one 
address. Beginning with the processing of tax year 2000 joint income 
tax returns, the IRS's automated masterfile will be able to retain a 
second address. Therefore, if the NCOA database contains change of 
address information for only one spouse from a joint return, the rules 
of this regulation will not apply to notices, statements, and other 
documents mailed before the processing of the taxpayers' tax year 2000 
joint income tax return.

Summary of Comments

    Commentators also suggested that these regulations refer to section 
6672(b)(1) and section 4103. Because section 6672(b)(1) requires that 
the IRS mail notices to the taxpayer's last known address, a cross-
reference under Sec. 301.6672-1 has been added to these regulations. 
However, because section 4103 does not require the IRS to mail notices 
to the taxpayer's last known address, no cross-reference is necessary.
    A third commentator suggested that the IRS coordinate these 
regulations with Rev. Proc. 90-18 (1990-1 C.B. 491). Rev. Proc. 90-18 
will be updated to incorporate changes made by these final regulations 
and to provide rules for oral notification of a change of address, 
additional tax forms from which taxpayer addresses will be updated, and 
additional Internal Revenue Code sections that require a notice be sent 
to a taxpayer's last known address.
    The commentator also asked what is the most recently filed return 
for purposes of Sec. 301.6212-2(a) of the regulations, i.e., whether 
different returns filed by the same taxpayer will update the taxpayer's 
last known address. The rules provided in these regulations do not in 
any way alter the existing rules for updating a taxpayer's last known 
address from a filed return. Section 5.01 of Rev. Proc. 90-18 provides 
which returns will update a taxpayer's last known address under a 
social security number or an employer identification number. Therefore, 
an amended return filed on a Form 1040X with a different address from 
that which appeared on the taxpayer's previously filed Form 1040 will 
update the taxpayer's last known address of record with the IRS. 
However, a Form 941 filed by a Schedule C business would not update the 
address for the taxpayer's individual income tax account as the Form 
941 is filed with an employer identification number and the individual 
income tax account is associated with the taxpayer's social security 
number.
    Finally, as mentioned above, the commentator noted that accessing 
the NCOA database for IRS Service Center mailings but not for district 
office mailings might cause confusion for taxpayers. As the procedures 
for updating taxpayer addresses are modified by these final 
regulations, there is no longer any difference between Service Center 
and other field or area office mailings.

Special Analyses

    It has been determined that this Treasury decision is not a 
significant regulatory action as defined in Executive Order 12866. 
Therefore, a regulatory assessment is not required. It also has been 
determined that section 553(b) of the Administrative Procedure Act (5 
U.S.C. chapter 5) does not apply to these regulations, and because 
these regulations do not impose a collection of information on small 
entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not 
apply. Pursuant to section 7805(f) of the Internal Revenue Code, the 
notice of proposed rulemaking preceding these regulations was submitted 
to the Chief Counsel for Advocacy of the Small Business Administration 
for comment on its impact on small business.

Drafting Information

    The principal author of these regulations is Charles A. Hall of the 
Office of Associate Chief Counsel, Procedure and Administration 
(Administrative Provisions and Judicial Practice Division). However, 
other personnel from the IRS and Treasury Department participated in 
their development.

List of Subjects

26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

26 CFR Part 301

    Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income 
taxes, Penalties, Reporting and recordkeeping requirements.

Adoption of Amendments to the Regulations

    Accordingly, 26 CFR parts 1 and 301 are amended as follows:

PART 1--INCOME TAXES

    Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805 * * *


    Par. 2. In Sec. 1.468A-5, paragraph (c)(1)(ii) is amended by adding 
a

[[Page 2819]]

sentence at the end of the paragraph to read as follows:


Sec. 1.468A-5  Nuclear decommissioning fund qualification requirements; 
prohibitions against self-dealing; disqualification of nuclear 
decommissioning fund; termination of fund upon substantial completion 
of decommissioning.

* * * * *
    (c) * * *
    (1) * * *
    (ii) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter.
* * * * *

    Par. 3. In Sec. 1.503(a)-1, paragraph (c) concluding text is 
amended by adding a sentence at the end of the paragraph to read as 
follows:


Sec. 1.503(a)-1  Denial of exemption to certain organizations engaged 
in prohibited transactions.

* * * * *
    (c) * * *

* * * For further guidance regarding the definition of last known 
address, see Sec. 301.6212-2 of this chapter.
* * * * *

    Par. 4. In Sec. 1.547-2, paragraph (b)(1)(v) is amended by adding a 
sentence after the third sentence of the paragraph to read as follows:


Sec. 1.547-2  Requirements for deficiency dividends.

* * * * *
    (b) * * *
    (1) * * *
    (v) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter. * * *
* * * * *

    Par. 5. In Sec. 1.856-6, paragraph (g)(5) is amended by adding a 
sentence after the first sentence of the paragraph to read as follows:


Sec. 1.856-6  Foreclosure property.

* * * * *
    (g) * * *
    (5) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter. * * *
* * * * *

    Par. 6. In Sec. 1.860-2, paragraph (b)(1)(ii) is amended by adding 
a sentence after the fourth sentence of the paragraph to read as 
follows:


Sec. 1.860-2  Requirements for deficiency dividends.

* * * * *
    (b) * * *
    (1) * * *
    (ii) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter. * * *
* * * * *

    Par. 7. In Sec. 1.963-6, paragraph (c)(5) is amended by adding a 
sentence after the second sentence of the paragraph to read as follows:


Sec. 1.963-6  Deficiency distribution.

* * * * *
    (c) * * *
    (5) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter. * * *
* * * * *
    Par. 8. In Sec. 1.992-3, paragraph (c)(3)(iv) is amended by adding 
a sentence after the third sentence of the paragraph to read as 
follows:


Sec. 1.992-3  Deficiency distributions to meet qualification 
requirements.

* * * * *
    (c) * * *
    (3) * * *
    (iv) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter. * * *
* * * * *

    Par. 9. In Sec. 1.6081-2, paragraph (f) is amended by adding a 
sentence at the end of the paragraph to read as follows:


Sec. 1.6081-2  Automatic extension of time to file partnership return 
of income.

* * * * *
    (f) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter.
* * * * *

    Par. 10. In Sec. 1.6081-3, paragraph (d) is amended by adding a 
sentence at the end of the paragraph to read as follows:


Sec. 1.6081-3  Automatic extension of time for filing corporation 
income tax returns.

* * * * *
    (d) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter.
* * * * *

    Par. 11. In Sec. 1.6081-4, paragraph (c) is amended by adding a 
sentence at the end of the paragraph to read as follows:


Sec. 1.6081-4  Automatic extension of time for filing individual income 
tax returns.

* * * * *
    (c) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter.
* * * * *

    Par. 12. In Sec. 1.6081-6, paragraph (d) is amended by adding a 
sentence at the end of the paragraph to read as follows:


Sec. 1.6081-6  Automatic extension of time to file trust income tax 
return.

* * * * *
    (d) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter.
* * * * *

    Par. 13. In Sec. 1.6081-7, paragraph (d) is amended by adding a 
sentence at the end of the paragraph to read as follows:


Sec. 1.6081-7  Automatic extension of time to file Real Estate Mortgage 
Investment Conduit (REMIC) income tax return.

* * * * *
    (d) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2 of this chapter.
* * * * *

PART 301--PROCEDURE AND ADMINISTRATION

    Par. 14. The authority citation for part 301 continues to read in 
part as follows:

    Authority: 26 U.S.C. 7805 * * *


    Par. 15. In Sec. 301.6110-4, paragraph (c)(3) is amended by adding 
a sentence at the end of the paragraph to read as follows:


Sec. 301.6110-4  Communications from third parties.

* * * * *
    (c) * * *
    (3) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2.
* * * * *

    Par. 16. In Sec. 301.6110-5, paragraph (b)(4) is amended by adding 
a sentence at the end of the paragraph to read as follows:


Sec. 301.6110-5  Notice and time requirements; actions to restrain 
disclosure; actions to obtain additional disclosure.

* * * * *
    (b) * * *
    (4) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2.
* * * * *

    Par. 17. In Sec. 301.6110-6, paragraph (b)(2)(v) is amended by 
adding a sentence at the end of the paragraph to read as follows:


Sec. 301.6110-6  Written determinations issued in response to requests 
submitted before November 1, 1976.

* * * * *

[[Page 2820]]

    (b) * * *
    (2) * * *
    (v) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2.
* * * * *

    Par. 18. Section 301.6212-2 is added to read as follows:


Sec. 301.6212-2  Definition of last known address.

    (a) General rule. Except as provided in paragraph (b)(2) of this 
section, a taxpayer's last known address is the address that appears on 
the taxpayer's most recently filed and properly processed Federal tax 
return, unless the Internal Revenue Service (IRS) is given clear and 
concise notification of a different address. Further information on 
what constitutes clear and concise notification of a different address 
and a properly processed Federal tax return can be found in Rev. Proc. 
90-18 (1990-1 C.B. 491) or in procedures subsequently prescribed by the 
Commissioner.
    (b) Address obtained from third party--(1) In general. Except as 
provided in paragraph (b)(2) of this section, change of address 
information that a taxpayer provides to a third party, such as a payor 
or another government agency, is not clear and concise notification of 
a different address for purposes of determining a last known address 
under this section.
    (2) Exception for address obtained from the United States Postal 
Service--(i) Updating taxpayer addresses. The IRS will update taxpayer 
addresses maintained in IRS records by referring to data accumulated 
and maintained in the United States Postal Service (USPS) National 
Change of Address database that retains change of address information 
for thirty-six months (NCOA database). Except as provided in paragraph 
(b)(2)(ii) of this section, if the taxpayer's name and last known 
address in IRS records match the taxpayer's name and old mailing 
address contained in the NCOA database, the new address in the NCOA 
database is the taxpayer's last known address, unless the IRS is given 
clear and concise notification of a different address.
    (ii) Duration of address obtained from NCOA database. The address 
obtained from the NCOA database under paragraph (b)(2)(i) of this 
section is the taxpayer's last known address until one of the following 
events occurs--
    (A) The taxpayer files and the IRS properly processes a Federal tax 
return with an address different from the address obtained from the 
NCOA database; or
    (B) The taxpayer provides the Internal Revenue Service with clear 
and concise notification of a change of address, as defined in 
procedures prescribed by the Commissioner, that is different from the 
address obtained from the NCOA database.
    (3) Examples. The following examples illustrate the rules of 
paragraph (b)(2) of this section:

    Example 1. (i) A is an unmarried taxpayer. The address on A's 
1999 Form 1040, U.S. Individual Income Tax Return, filed on April 
14, 2000, and 2000 Form 1040 filed on April 13, 2001, is 1234 
Anyplace Street, Anytown, USA 43210. On May 15, 2001, A informs the 
USPS of a new permanent address (9876 Newplace Street, Newtown, USA 
12345) using the USPS Form 3575, ``Official Mail Forwarding Change 
of Address Form.'' The change of address is included in the weekly 
update of the USPS NCOA database. On May 29, 2001, A's address 
maintained in IRS records is changed to 9876 Newplace Street, 
Newtown, USA 12345.
    (ii) In June 2001 the IRS determines a deficiency for A's 1999 
tax year and prepares to issue a notice of deficiency. The IRS 
obtains A's address for the notice of deficiency from IRS records. 
On June 15, 2001, the Internal Revenue Service mails the notice of 
deficiency to A at 9876 Newplace Street, Newtown, USA 12345. For 
purposes of section 6212(b), the notice of deficiency mailed on June 
15, 2001, is mailed to A's last known address.
    Example 2. (i) The facts are the same as in Example 1, except 
that instead of determining a deficiency for A's 1999 tax year in 
June 2001, the IRS determines a deficiency for A's 1999 tax year in 
May 2001.
    (ii) On May 21, 2001, the IRS prepares a notice of deficiency 
for A and obtains A's address from IRS records. Because A did not 
inform the USPS of the change of address in sufficient time for the 
IRS to process and post the new address in Internal Revenue 
Service's records by May 21, 2001, the notice of deficiency is 
mailed to 1234 Anyplace Street, Anytown, USA 43210. For purposes of 
section 6212(b), the notice of deficiency mailed on May 21, 2001, is 
mailed to A's last known address.
    Example 3.  (i) C and D are married taxpayers. The address on C 
and D's 2000 Form 1040, U.S. Individual Income Tax Return, filed on 
April 13, 2001, and 2001 Form 1040 filed on April 15, 2002, is 2468 
Spring Street, Little City, USA 97531. On August 15, 2002, D informs 
the USPS of a new permanent address (8642 Peachtree Street, Big 
City, USA 13579) using the USPS Form 3575, ``Official Mail 
Forwarding Change of Address Form.'' The change of address is 
included in the weekly update of the USPS NCOA database. On August 
29, 2002, D's address maintained in IRS records is changed to 8642 
Peachtree Street, Big City, USA 13579.
    (ii) In October 2002 the IRS determines a deficiency for C and 
D's 2000 tax year and prepares to issue a notice of deficiency. The 
Internal Revenue Service obtains C's address and D's address for the 
notice of deficiency from IRS records. On October 15, 2002, the IRS 
mails a copy of the notice of deficiency to C at 2468 Spring Street, 
Little City, USA 97531, and to D at 8642 Peachtree Street, Big City, 
USA 13579. For purposes of section 6212(b), the notices of 
deficiency mailed on October 15, 2002, are mailed to C and D's 
respective last known addresses.

    (c) Last known address for all notices, statements, and documents. 
The rules in paragraphs (a) and (b) of this section apply for purposes 
of determining whether all notices, statements, or other documents are 
mailed to a taxpayer's last known address whenever the term last known 
address is used in the Internal Revenue Code or the regulations 
thereunder.
    (d) Effective Date--(1) In general. Except as provided in paragraph 
(d)(2) of this section, this section is effective on January 29, 2001.
    (2) Individual moves in the case of joint filers. In the case of 
taxpayers who file joint returns under section 6013, if the NCOA 
database contains change of address information for only one spouse, 
paragraphs (b)(2) and (3) of this section will not apply to notices, 
statements, and other documents mailed before the processing of the 
taxpayers' 2000 joint return.

    Par. 19. In Sec. 301.6303-1, paragraph (a) is amended by adding a 
sentence at the end of the paragraph to read as follows:


Sec. 301.6303-1  Notice and demand for tax.

* * * * *
    (a) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2.
* * * * *

    Par. 20. In Sec. 301.6305-1, paragraph (b)(2)(ii) is revised to 
read as follows:


Sec. 301.6305-1  Assessment and collection of certain liability.

* * * * *
    (b) * * *
    (2) * * *
    (ii) The name, social security number, and last known address of 
the individual owing the assessed amount. For further guidance 
regarding the definition of last known address, see Sec. 301.6212-2;
* * * * *

    Par. 21. In Sec. 301.6320-1T, paragraph (a)(1) is amended by adding 
a sentence at the end of the paragraph to read as follows:


Sec. 301.6320-1T  Notice and opportunity for hearing upon filing of 
notice of Federal tax lien (temporary).

    (a) * * *
    (1) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2.
* * * * *

[[Page 2821]]


    Par. 22. In Sec. 301.6325-1, paragraph (f)(2)(ii)(a) is revised to 
read as follows:


Sec. 301.6325-1  Release of lien or discharge of property.

* * * * *
    (f) * * *
    (2) * * *
    (ii) * * *
    (a) Mailing notice of the revocation to the taxpayer at his last 
known address (see Sec. 301.6212-2 for further guidance regarding the 
definition of last known address); and
* * * * *

    Par. 23. In Sec. 301.6330-1T, paragraph (a)(1) is amended by adding 
a sentence at the end of the paragraph to read as follows:


Sec. 301.6330-1T  Notice and opportunity for hearing prior to levy 
(temporary).

    (a) * * *
    (1) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2.
* * * * *

    Par. 24. In Sec. 301.6331-2, paragraph (a)(1) is amended by adding 
a sentence after the second sentence of the paragraph to read as 
follows:


Sec. 301.6331-2  Procedures and restrictions on levies.

    (a) * * *
    (1) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2. * * *
* * * * *

    Par. 25. Section 301.6332-2 is amended as follows:
    1. Paragraphs (b)(1) introductory text, (b)(1)(i), and (b)(1)(ii) 
are redesignated as paragraphs (b)(1)(i) introductory text, 
(b)(1)(i)(A), and (b)(1)(i)(B), respectively.
    2. In newly designated paragraph (b)(1)(i)(B), the text beginning 
with the second sentence is redesignated as paragraph (b)(1)(ii).
    3. Newly designated paragraph (b)(1)(ii) is amended by adding a 
sentence after the second sentence of the paragraph.
    The addition reads as follows:


Sec. 301.6332-2  Surrender of property subject to levy in the case of 
life insurance and endowment contracts.

* * * * *
    (b) * * *
    (1) In general.
    (ii) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2. * * *
* * * * *
    Par. 26. In Sec. 301.6335-1, paragraph (b)(1) is amended by adding 
a sentence after the third sentence of the paragraph to read as 
follows:


Sec. 301.6335-1  Sale of seized property.

* * * * *
    (b) * * *
    (1) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2. * * *
* * * * *

    Par. 27. In Sec. 301.6503(c)-1, paragraph (a) is amended by adding 
a sentence at the end of the paragraph to read as follows:


Sec. 301.6503(c)-1  Suspension of running of period of limitation; 
location of property outside the United States or removal of property 
from the United States; taxpayer outside of United States.

    (a) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2.
* * * * *

    Par. 28. Section 301.6672-1 is amended by adding a sentence at the 
end of the section to read as follows:


Sec. 301.6672-1  Failure to collect and pay over tax, or attempt to 
evade or defeat tax.

* * * For further guidance regarding the determination of the proper 
address for mailing the notice required under section 6672(b)(1), see 
Sec. 301.6212-2.

    Par. 29. In Sec. 301.6903-1, paragraph (c) is amended by adding a 
sentence after the first sentence of the paragraph to read as follows:


Sec. 301.6903-1  Notice of fiduciary relationship.

* * * * *
    (c) * * * For further guidance regarding the definition of last 
known address, see Sec. 301.6212-2. * * *
* * * * *

Robert E. Wenzel,
Deputy Commissioner of Internal Revenue.
    Approved: December 11, 2000.
Jonathan Talisman,
Acting Assistant Secretary of the Treasury.
[FR Doc. 01-623 Filed 1-11-01; 8:45 am]
BILLING CODE 4830-01-U