SCOPE OF WAIVER OF STATUTE OF LIMITATIONS IN CASE OF ACTIVITIES NOT ENGAGED IN FOR PROFIT.

SEC. 214. SCOPE OF WAIVER OF STATUTE OF LIMITATIONS IN CASE OF ACTIVITIES NOT ENGAGED IN FOR PROFIT. (a) In General.— Subsection (e) of section 183 (relating to special rule for activities not engaged in for profit) is amended by adding at the end thereof the following new paragraph: “(4) Time for assessing deficiency attributable to activity.— If a taxpayer makes an election under paragraph (1) with respect to an activity, the statutory period for the assessment of any deficiency attributable to such activity shall not expire before the expiration of 2 years after the date prescribed by law (determined without extensions) for filing the return of tax under chapter 1 for the hist taxable year in the period of 5 taxable years (or 7 taxable years) to which the election relates. Such deficiency may be assessed notwithstanding the provisions of any law or rule of law which would otherwise prevent such an assessment.”. (b) Cross Reference.— Paragraph (2) of section 6212(c) (relating to restriction of further deficiency letters) is amended by adding at the end thereof the following new subparagraph: “(E) Deficiency attributable to activities not engaged in tor profit, see section 183(e)(4).”. (c) Effective Date.— The amendments made by this section shall apply with respect to taxable years beginning after December 31, 1969; except that such amendments shall not apply to any taxable year ending before the date of the enactment of this Act with respect to which the period for assessing a deficiency has expired before such date of enactment.