
From the U.S. Code Online via GPO Access
[wais.access.gpo.gov]
[Laws in effect as of January 2, 2001]
[Document not affected by Public Laws enacted between
  January 2, 2001 and January 28, 2002]
[CITE: 26USC6402]

 
                     TITLE 26--INTERNAL REVENUE CODE
 
                Subtitle F--Procedure and Administration
 
              CHAPTER 65--ABATEMENTS, CREDITS, AND REFUNDS
 
                   Subchapter A--Procedure in General
 
Sec. 6402. Authority to make credits or refunds


(a) General rule

    In the case of any overpayment, the Secretary, within the applicable 
period of limitations, may credit the amount of such overpayment, 
including any interest allowed thereon, against any liability in respect 
of an internal revenue tax on the part of the person who made the 
overpayment and shall, subject to subsections (c), (d), and (e) refund 
any balance to such person.

(b) Credits against estimated tax

    The Secretary is authorized to prescribe regulations providing for 
the crediting against the estimated income tax for any taxable year of 
the amount determined by the taxpayer or the Secretary to be an 
overpayment of the income tax for a preceding taxable year.

(c) Offset of past-due support against overpayments

    The amount of any overpayment to be refunded to the person making 
the overpayment shall be reduced by the amount of any past-due support 
(as defined in section 464(c) of the Social Security Act) owed by that 
person of which the Secretary has been notified by a State in accordance 
with section 464 of the Social Security Act. The Secretary shall remit 
the amount by which the overpayment is so reduced to the State 
collecting such support and notify the person making the overpayment 
that so much of the overpayment as was necessary to satisfy his 
obligation for past-due support has been paid to the State. A reduction 
under this subsection shall be applied first to satisfy any past-due 
support which has been assigned to the State under section 402(a)(26) 
\1\ or 471(a)(17) of the Social Security Act, and shall be applied to 
satisfy any other past-due support after any other reductions allowed by 
law (but before a credit against future liability for an internal 
revenue tax) have been made. This subsection shall be applied to an 
overpayment prior to its being credited to a person's future liability 
for an internal revenue tax.
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    \1\ See References in Text note below.
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(d) Collection of debts owed to Federal agencies

                           (1) In general

        Upon receiving notice from any Federal agency that a named 
    person owes a past-due legally enforceable debt (other than past-due 
    support subject to the provisions of subsection (c)) to such agency, 
    the Secretary shall--
            (A) reduce the amount of any overpayment payable to such 
        person by the amount of such debt;
            (B) pay the amount by which such overpayment is reduced 
        under subparagraph (A) to such agency; and
            (C) notify the person making such overpayment that such 
        overpayment has been reduced by an amount necessary to satisfy 
        such debt.

                      (2) Priorities for offset

        Any overpayment by a person shall be reduced pursuant to this 
    subsection after such overpayment is reduced pursuant to subsection 
    (c) with respect to past-due support collected pursuant to an 
    assignment under section 402(a)(26) \1\ of the Social Security Act 
    and before such overpayment is reduced pursuant to subsection (e) 
    and before such overpayment is credited to the future liability for 
    tax of such person pursuant to subsection (b). If the Secretary 
    receives notice from a Federal agency or agencies of more than one 
    debt subject to paragraph (1) that is owed by a person to such 
    agency or agencies, any overpayment by such person shall be applied 
    against such debts in the order in which such debts accrued.

                 (3) Treatment of OASDI overpayments

        (A) Requirements

            Paragraph (1) shall apply with respect to an OASDI 
        overpayment only if the requirements of paragraphs (1) and (2) 
        of section 3720A(f) of title 31, United States Code, are met 
        with respect to such overpayment.

        (B) Notice; protection of other persons filing joint return

            (i) Notice

                In the case of a debt consisting of an OASDI 
            overpayment, if the Secretary determines upon receipt of the 
            notice referred to in paragraph (1) that the refund from 
            which the reduction described in paragraph (1)(A) would be 
            made is based upon a joint return, the Secretary shall--
                    (I) notify each taxpayer filing such joint return 
                that the reduction is being made from a refund based 
                upon such return, and
                    (II) include in such notification a description of 
                the procedures to be followed, in the case of a joint 
                return, to protect the share of the refund which may be 
                payable to another person.
            (ii) Adjustments based on protections given to other 
                    taxpayers on joint return

                If the other person filing a joint return with the 
            person owing the OASDI overpayment takes appropriate action 
            to secure his or her proper share of the refund subject to 
            reduction under this subsection, the Secretary shall pay 
            such share to such other person. The Secretary shall deduct 
            the amount of such payment from amounts which are derived 
            from subsequent reductions in refunds under this subsection 
            and are payable to a trust fund referred to in subparagraph 
            (C).

        (C) Deposit of amount of reduction into appropriate trust fund

            In lieu of payment, pursuant to paragraph (1)(B), of the 
        amount of any reduction under this subsection to the 
        Commissioner of Social Security, the Secretary shall deposit 
        such amount in the Federal Old-Age and Survivors Insurance Trust 
        Fund or the Federal Disability Insurance Trust Fund, whichever 
        is certified to the Secretary as appropriate by the Commissioner 
        of Social Security.

        (D) OASDI overpayment

            For purposes of this paragraph, the term ``OASDI 
        overpayment'' means any overpayment of benefits made to an 
        individual under title II of the Social Security Act.

(e) Collection of past-due, legally enforceable State income tax 
        obligations

                           (1) In general

        Upon receiving notice from any State that a named person owes a 
    past-due, legally enforceable State income tax obligation to such 
    State, the Secretary shall, under such conditions as may be 
    prescribed by the Secretary--
            (A) reduce the amount of any overpayment payable to such 
        person by the amount of such State income tax obligation;
            (B) pay the amount by which such overpayment is reduced 
        under subparagraph (A) to such State and notify such State of 
        such person's name, taxpayer identification number, address, and 
        the amount collected; and
            (C) notify the person making such overpayment that the 
        overpayment has been reduced by an amount necessary to satisfy a 
        past-due, legally enforceable State income tax obligation.

    If an offset is made pursuant to a joint return, the notice under 
    subparagraph (B) shall include the names, taxpayer identification 
    numbers, and addresses of each person filing such return.

    (2) Offset permitted only against residents of State seeking 
                                   offset

        Paragraph (1) shall apply to an overpayment by any person for a 
    taxable year only if the address shown on the Federal return for 
    such taxable year of the overpayment is an address within the State 
    seeking the offset.

                      (3) Priorities for offset

        Any overpayment by a person shall be reduced pursuant to this 
    subsection--
            (A) after such overpayment is reduced pursuant to--
                (i) subsection (a) with respect to any liability for any 
            internal revenue tax on the part of the person who made the 
            overpayment;
                (ii) subsection (c) with respect to past-due support; 
            and
                (iii) subsection (d) with respect to any past-due, 
            legally enforceable debt owed to a Federal agency; and

            (B) before such overpayment is credited to the future 
        liability for any Federal internal revenue tax of such person 
        pursuant to subsection (b).

    If the Secretary receives notice from one or more agencies of the 
    State of more than one debt subject to paragraph (1) that is owed by 
    such person to such an agency, any overpayment by such person shall 
    be applied against such debts in the order in which such debts 
    accrued.

                (4) Notice; consideration of evidence

        No State may take action under this subsection until such 
    State--
            (A) notifies by certified mail with return receipt the 
        person owing the past-due State income tax liability that the 
        State proposes to take action pursuant to this section;
            (B) gives such person at least 60 days to present evidence 
        that all or part of such liability is not past-due or not 
        legally enforceable;
            (C) considers any evidence presented by such person and 
        determines that an amount of such debt is past-due and legally 
        enforceable; and
            (D) satisfies such other conditions as the Secretary may 
        prescribe to ensure that the determination made under 
        subparagraph (C) is valid and that the State has made reasonable 
        efforts to obtain payment of such State income tax obligation.

         (5) Past-due, legally enforceable State income tax 
                                 obligation

        For purposes of this subsection, the term ``past-due, legally 
    enforceable State income tax obligation'' means a debt--
            (A)(i) which resulted from--
                (I) a judgment rendered by a court of competent 
            jurisdiction which has determined an amount of State income 
            tax to be due; or
                (II) a determination after an administrative hearing 
            which has determined an amount of State income tax to be 
            due; and

            (ii) which is no longer subject to judicial review; or
            (B) which resulted from a State income tax which has been 
        assessed but not collected, the time for redetermination of 
        which has expired, and which has not been delinquent for more 
        than 10 years.

    For purposes of this paragraph, the term ``State income tax'' 
    includes any local income tax administered by the chief tax 
    administration agency of the State.

                           (6) Regulations

        The Secretary shall issue regulations prescribing the time and 
    manner in which States must submit notices of past-due, legally 
    enforceable State income tax obligations and the necessary 
    information that must be contained in or accompany such notices. The 
    regulations shall specify the types of State income taxes and the 
    minimum amount of debt to which the reduction procedure established 
    by paragraph (1) may be applied. The regulations may require States 
    to pay a fee to reimburse the Secretary for the cost of applying 
    such procedure. Any fee paid to the Secretary pursuant to the 
    preceding sentence shall be used to reimburse appropriations which 
    bore all or part of the cost of applying such procedure.

                   (7) Erroneous payment to State

        Any State receiving notice from the Secretary that an erroneous 
    payment has been made to such State under paragraph (1) shall pay 
    promptly to the Secretary, in accordance with such regulations as 
    the Secretary may prescribe, an amount equal to the amount of such 
    erroneous payment (without regard to whether any other amounts 
    payable to such State under such paragraph have been paid to such 
    State).

(f) Review of reductions

    No court of the United States shall have jurisdiction to hear any 
action, whether legal or equitable, brought to restrain or review a 
reduction authorized by subsection (c), (d), or (e). No such reduction 
shall be subject to review by the Secretary in an administrative 
proceeding. No action brought against the United States to recover the 
amount of any such reduction shall be considered to be a suit for refund 
of tax. This subsection does not preclude any legal, equitable, or 
administrative action against the Federal agency or State to which the 
amount of such reduction was paid or any such action against the 
Commissioner of Social Security which is otherwise available with 
respect to recoveries of overpayments of benefits under section 204 of 
the Social Security Act.

(g) Federal agency

    For purposes of this section, the term ``Federal agency'' means a 
department, agency, or instrumentality of the United States, and 
includes a Government corporation (as such term is defined in section 
103 of title 5, United States Code).

(h) Treatment of payments to States

    The Secretary may provide that, for purposes of determining 
interest, the payment of any amount withheld under subsection (c) or (e) 
to a State shall be treated as a payment to the person or persons making 
the overpayment.

(i) Cross reference

    For procedures relating to agency notification of the Secretary, see 
section 3721 of title 31, United States Code.

(j) Refunds to certain fiduciaries of insolvent members of affiliated 
        groups

    Notwithstanding any other provision of law, in the case of an 
insolvent corporation which is a member of an affiliated group of 
corporations filing a consolidated return for any taxable year and which 
is subject to a statutory or court-appointed fiduciary, the Secretary 
may by regulation provide that any refund for such taxable year may be 
paid on behalf of such insolvent corporation to such fiduciary to the 
extent that the Secretary determines that the refund is attributable to 
losses or credits of such insolvent corporation.

(k) Explanation of reason for refund disallowance

    In the case of a disallowance of a claim for refund, the Secretary 
shall provide the taxpayer with an explanation for such disallowance.

(Aug. 6, 1954, ch. 736, 68A Stat. 791; Pub. L. 94-455, title XIX, 
Sec. 1906(b)(13) (A), (K), Oct. 4, 1976, 90 Stat. 1834, 1835; Pub. L. 
97-35, title XXIII, Sec. 2331(c), Aug. 13, 1981, 95 Stat. 861; Pub. L. 
98-369, div. B, title VI, Sec. 2653(b)(1), (2), July 18, 1984, 98 Stat. 
1154, 1155; Pub. L. 98-378, Sec. 21(e), Aug. 16, 1984, 98 Stat. 1325; 
Pub. L. 100-647, title VI, Sec. 6276, Nov. 10, 1988, 102 Stat. 3753; 
Pub. L. 101-508, title V, Sec. 5129(c), Nov. 5, 1990, 104 Stat. 1388-
288; Pub. L. 103-296, title I, Sec. 108(h)(7), Aug. 15, 1994, 108 Stat. 
1487; Pub. L. 104-134, title III, Sec. 31001(u)(2), Apr. 26, 1996, 110 
Stat. 1321-375; Pub. L. 104-193, title I, Sec. 110(l)(7), Aug. 22, 1996, 
110 Stat. 2173; Pub. L. 105-33, title V, Sec. 5514(a)(1), Aug. 5, 1997, 
111 Stat. 620; Pub. L. 105-206, title III, Secs. 3505(a), 3711(a), (c), 
July 22, 1998, 112 Stat. 771, 779, 781.)

                       References in Text

    The Social Security Act, referred to in subsecs. (c), (d)(2), 
(3)(D), and (f), is act Aug. 14, 1935, ch. 531, 49 Stat. 620, as 
amended. Title II of the Act is classified generally to subchapter II 
(Sec. 401 et seq.) of chapter 7 of Title 42, The Public Health and 
Welfare. Sections 204, 464, and 471(a)(17) of the Act are classified to 
sections 404, 664, and 671(a)(17) of Title 42. Section 402 of the Act, 
which was classified to section 602 of Title 42, was repealed and a new 
section 402 enacted by Pub. L. 104-193, title I, Sec. 103(a)(1), Aug. 
22, 1996, 110 Stat. 2112. As so enacted section 402 does not contain a 
subsec. (a)(26). For complete classification of this Act to the Code, 
see section 1305 of Title 42 and Tables.


                               Amendments

    1998--Subsec. (a). Pub. L. 105-206, Sec. 3711(c)(1), substituted 
``(c), (d), and (e)'' for ``(c) and (d)''.
    Subsec. (d)(2). Pub. L. 105-206, Sec. 3711(c)(2), substituted ``and 
before such overpayment is reduced pursuant to subsection (e) and before 
such overpayment'' for ``and before such overpayment''.
    Subsec. (e). Pub. L. 105-206, Sec. 3711(a), added subsec. (e). 
Former subsec. (e) redesignated (f).
    Subsec. (f). Pub. L. 105-206, Sec. 3711(a), (c)(3), redesignated 
subsec. (e) as (f) and substituted ``(c), (d), or (e)'' for ``(c) or 
(d)'' and ``Federal agency or State'' for ``Federal agency''. Former 
subsec. (f) redesignated (g).
    Subsec. (g). Pub. L. 105-206, Sec. 3711(a), redesignated subsec. (f) 
as (g). Former subsec. (g) redesignated (h).
    Subsec. (h). Pub. L. 105-206, Sec. 3711(a), (c)(4), redesignated 
subsec. (g) as (h) and substituted ``subsection (c) or (e)'' for 
``subsection (c)''. Former subsec. (h) redesignated (i).
    Subsec. (i). Pub. L. 105-206, Sec. 3711(a), redesignated subsec. (h) 
as (i). Former subsec. (i) redesignated (j).
    Subsec. (j). Pub. L. 105-206, Sec. 3711(a), redesignated subsec. (i) 
as (j). Former subsec. (j) redesignated (k).
    Pub. L. 105-206, Sec. 3505(a), added subsec. (j).
    Subsec. (k). Pub. L. 105-206, Sec. 3711(a), redesignated subsec. (j) 
as (k).
    1997--Subsecs. (a), (e) to (j). Pub. L. 105-33 repealed Pub. L. 104-
193, Sec. 110(l)(7). See 1996 Amendment notes below.
    1996--Subsec. (a). Pub. L. 104-193, Sec. 110(l)(7)(A), which 
directed substitution of ``(c), (d), and (e)'' for ``(c) and (d)'', was 
repealed by Pub. L. 105-33.
    Subsec. (e). Pub. L. 104-193, Sec. 110(l)(7)(C), which directed 
amendment by adding subsec. (e), reading as follows: ``Collection of 
Overpayments Under Title IV-A of the Social Security Act.--The amount of 
any overpayment to be refunded to the person making the overpayment 
shall be reduced (after reductions pursuant to subsections (c) and (d), 
but before a credit against future liability for an internal revenue 
tax) in accordance with section 405(e) of the Social Security Act 
(concerning recovery of overpayments to individuals under State plans 
approved under part A of title IV of such Act).'', was repealed by Pub. 
L. 105-33.
    Subsec. (f). Pub. L. 104-193, Sec. 110(l)(7)(B), which directed 
amendment by redesignating subsec. (e) as (f), was repealed by Pub. L. 
105-33.
    Pub. L. 104-134 amended subsec. (f) generally. Prior to amendment, 
subsec. (f) read as follows: ``For purposes of this section, the term 
`Federal agency' means a department, agency, or instrumentality of the 
United States (other than an agency subject to section 9 of the Act of 
May 18, 1933 (48 Stat. 63, chapter 32; 16 U.S.C. 831h)), and includes a 
Government corporation (as such term is defined in section 103 of title 
5, United States Code).''
    Subsecs. (g) to (j). Pub. L. 104-193, Sec. 110(l)(7)(B), which 
directed amendment by redesignating subsecs. (f) to (i) as (g) to (j), 
respectively, was repealed by Pub. L. 105-33.
    1994--Subsecs. (d)(3)(C), (e). Pub. L. 103-296 substituted 
``Commissioner of Social Security'' for ``Secretary of Health and Human 
Services'' wherever appearing.
    1990--Subsec. (d)(1). Pub. L. 101-508, Sec. 5129(c)(1)(A), struck 
out ``any OASDI overpayment and'' after ``(other than''.
    Subsec. (d)(3). Pub. L. 101-508, Sec. 5129(c)(1)(B), added par. (3) 
and struck out former par. (3) which read as follows: ``For purposes of 
this subsection the term `OASDI overpayment' means any overpayment of 
benefits made to an individual under title II of the Social Security 
Act.''
    Subsec. (e). Pub. L. 101-508, Sec. 5129(c)(2), inserted before 
period at end ``or any such action against the Secretary of Health and 
Human Services which is otherwise available with respect to recoveries 
of overpayments of benefits under section 204 of the Social Security 
Act''.
    1988--Subsec. (i). Pub. L. 100-647 added subsec. (i).
    1984--Subsec. (a). Pub. L. 98-369, Sec. 2653(b)(2), substituted 
``subsections (c) and (d)'' for ``subsection (c)''.
    Subsec. (c). Pub. L. 98-378, Sec. 21(e)(1), substituted ``collecting 
such support'' for ``to which such support has been assigned'' and 
inserted provision that a reduction under this subsection shall be 
applied first to satisfy any past-due support which has been assigned to 
the State under section 402(a)(26) or 471(a)(17) of the Social Security 
Act, and shall be applied to satisfy any other past-due support after 
any other reductions allowed by law (but before a credit against future 
liability for an internal revenue tax) have been made.
    Subsecs. (d) to (f). Pub. L. 98-369, Sec. 2653(b)(1), added subsecs. 
(d) to (f).
    Subsec. (g). Pub. L. 98-378, Sec. 21(e)(2), added subsec. (g). 
Former subsec. (g) redesignated (h).
    Pub. L. 98-369, Sec. 2653(b)(1), added subsec. (g).
    Subsec. (h). Pub. L. 98-378, Sec. 21(e)(2), redesignated former 
subsec. (g) as (h).
    1981--Subsec. (a). Pub. L. 97-35, Sec. 2331(c)(1), inserted 
reference to subsec. (c) of this section.
    Subsec. (c). Pub. L. 97-35, Sec. 2331(c)(2), added subsec. (c).
    1976--Pub. L. 94-455 struck out ``or his delegate'' after 
``Secretary'' wherever appearing.


                    Effective Date of 1998 Amendment

    Pub. L. 105-206, title III, Sec. 3505(b), July 22, 1998, 112 Stat. 
771, provided that: ``The amendment made by this section [amending this 
section] shall apply to disallowances after the 180th day after the date 
of the enactment of this Act [July 22, 1998].''
    Amendment by section 3711 of Pub. L. 105-206 applicable to refunds 
payable under this section after Dec. 31, 1999, see section 3711(d) of 
Pub. L. 105-206, set out as a note under section 6103 of this title.


                    Effective Date of 1997 Amendment

    Amendment by Pub. L. 105-33 effective as if included in section 110 
of the Personal Responsibility and Work Opportunity Reconciliation Act 
of 1996, Pub. L. 104-193, at the time such section 110 became law, see 
section 5518(c) of Pub. L. 105-33, set out as a note under section 51 of 
this title.


                    Effective Date of 1996 Amendment

    Amendment by Pub. L. 104-193 effective July 1, 1997, with transition 
rules relating to State options to accelerate such date, rules relating 
to claims, actions, and proceedings commenced before such date, rules 
relating to closing out of accounts for terminated or substantially 
modified programs and continuance in office of Assistant Secretary for 
Family Support, and provisions relating to termination of entitlement 
under AFDC program, see section 116 of Pub. L. 104-193, as amended, set 
out as an Effective Date note under section 601 of Title 42, The Public 
Health and Welfare.


                    Effective Date of 1994 Amendment

    Amendment by Pub. L. 103-296 effective Mar. 31, 1995, see section 
110(a) of Pub. L. 103-296, set out as a note under section 401 of Title 
42, The Public Health and Welfare.


                    Effective Date of 1990 Amendment

    Section 5129(d) of Pub. L. 101-508 provided that: ``The amendments 
made by this section [amending this section, section 3720A of Title 31, 
Money and Finance, and section 404 of Title 42, The Public Health and 
Welfare]--
        ``(1) shall take effect January 1, 1991, and
        ``(2) shall not apply to refunds to which the amendments made by 
    section 2653 of the Deficit Reduction Act of 1984 (98 Stat. 1153) 
    [enacting section 3720A of Title 31 and amending this section and 
    sections 6103 and 7213 of this title] do not apply.''


                    Effective Date of 1984 Amendments

    Amendment by Pub. L. 98-378 applicable with respect to refunds 
payable under this section after Dec. 31, 1985, see section 21(g) of 
Pub. L. 98-378, set out as a note under section 6103 of this title.
    Section 2653(c) of Pub. L. 98-369, as amended by Pub. L. 99-514, 
Sec. 2, Oct. 22, 1986, 100 Stat. 2095; Pub. L. 100-203, title IX, 
Sec. 9402(a), Dec. 22, 1987, 101 Stat. 1330-376; Pub. L. 100-485, title 
VII, Sec. 701(a), Oct. 13, 1988, 102 Stat. 2425; Pub. L. 102-164, title 
IV, Sec. 401(a), Nov. 15, 1991, 105 Stat. 1061, provided that: ``The 
amendments made by this section [enacting section 3720A of Title 31, 
Money and Finance, and amending this section and sections 6103 and 7213 
of this title] shall apply with respect to refunds payable under section 
6402 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] after 
December 31, 1985.''
    [Pub. L. 102-164, title IV, Sec. 401(b), Nov. 15, 1991, 105 Stat. 
1061, provided that: ``The amendment made by this section [amending 
section 2653(c) of Pub. L. 98-369, set out above] shall take effect on 
October 1, 1991.'']


                    Effective Date of 1981 Amendment

    Amendment by Pub. L. 97-35 effective, except as otherwise 
specifically provided, on Oct. 1, 1981, see section 2336 of Pub. L. 97-
35, set out as a note under section 651 of Title 42, The Public Health 
and Welfare.


 Organ and Tissue Donation Information Included With Income Tax Refund 
                                Payments

    Pub. L. 104-191, title III, Sec. 371, Aug. 21, 1996, 110 Stat. 2072, 
provided that:
    ``(a) In General.--The Secretary of the Treasury shall, to the 
extent practicable, include with the mailing of any payment of a refund 
of individual income tax made during the period beginning on February 1, 
1997, and ending on June 30, 1997, a copy of the document described in 
subsection (b).
    ``(b) Text of Document.--The Secretary of the Treasury shall, after 
consultation with the Secretary of Health and Human Services and 
organizations promoting organ and tissue (including eye) donation, 
prepare a document suitable for inclusion with individual income tax 
refund payments which--
        ``(1) encourages organ and tissue donation;
        ``(2) includes a detachable organ and tissue donor card; and
        ``(3) urges recipients to--
            ``(A) sign the organ and tissue donor card;
            ``(B) discuss organ and tissue donation with family members 
        and tell family members about the recipient's desire to be an 
        organ and tissue donor if the occasion arises; and
            ``(C) encourage family members to request or authorize organ 
        and tissue donation if the occasion arises.''


   Clarification of Congressional Intent as to Scope of Amendments by 
                     Section 2653 of Pub. L. 98-369

    Pub. L. 100-203, title IX, Sec. 9402(b), Dec. 22, 1987, 101 Stat. 
1330-376, provided that:
    ``(1) Nothing in the amendments made by section 2653 of the Deficit 
Reduction Act of 1984 [enacting section 3720A of Title 31, Money and 
Finance, and amending this section and sections 6103 and 7213 of this 
title] shall be construed as exempting debts of corporations or any 
other category of persons from the application of such amendments.
    ``(2) It is the intent of the Congress that, to the extent 
practicable, the amendments made by section 2653 of the Deficit 
Reduction Act of 1984 shall extend to all Federal agencies (as defined 
in the amendments made by such section).
    ``(3) The Secretary of the Treasury shall issue regulations to carry 
out the purposes of this subsection.''


  Study by General Accounting Office of Operation and Effectiveness of 
              Amendments by Section 2653 of Pub. L. 98-369

    Pub. L. 100-203, title IX, Sec. 9402(c), Dec. 22, 1987, 101 Stat. 
1330-376, provided that: ``The Comptroller General of the United States, 
in consultation with the Secretary of the Treasury or his delegate, 
shall conduct a study of the operation and effectiveness of the 
amendments made by section 2653 of the Deficit Reduction Act of 1984 
[enacting section 3720A of Title 31, Money and Finance, and amending 
this section and sections 6103 and 7213 of this title]. The study shall 
compile and evaluate information on the effect of those amendments on 
voluntary compliance with the income tax laws. Not later than April 1, 
1989, the Comptroller General shall submit to the Committee on Ways and 
Means of the House of Representatives and the Committee on Finance of 
the Senate a report of the study conducted under this subsection, 
together with such recommendations as he may deem advisable.''

                  Section Referred to in Other Sections

    This section is referred to in sections 6103, 6331, 6403, 6512, 
6513, 6861, 9502 of this title; title 42 section 664.
