TAXPAYERS MAY RELY ON WRITTEN ADVICE OF INTERNAL REVENUE SERVICE.

SEC. 6229. TAXPAYERS MAY RELY ON WRITTEN ADVICE OF INTERNAL REVENUE SERVICE. (a) In General.—Section 6404 of the 1986 Code (relating to abatements) is amended by adding at the end thereof the following new subsection: “(f) Abatement of Any Penalty or Addition to Tax Attributable to Erroneous Written Advice by the Internal Revenue Service.— “(1) In general.—The Secretary shall abate any portion of any penalty or addition to tax attributable to erroneous advice furnished to the taxpayer in writing by an officer or employee of the Internal Revenue Service, acting in such officer’s or employee’s official capacity. “(2) Limitations.— Paragraph (1) shall apply only if— “(A) the written advice was reasonably relied upon by the taxpayer and was in response to a specific written request of the taxpayer, and “(B) the portion of the penalty or addition to tax did not result from a failure by the taxpayer to provide adequate or accurate information. “(3) Initial regulations.—Within 180 days after the date of the enactment of this subsection, the Secretary shall prescribe such initial regulations as may be necessary to carry out this subsection.” (b) Effective Date.—The amendment made by subsection (a) shall apply with respect to advice requested on or after January 1, 1989.