[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6503(c)-1]

[Page 376-377]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                               Limitations
 
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) Property located outside, or removed from, the United States 
prior to November 3, 1966. The running of the period of limitations on 
collection after assessment prescribed in section 6502 is suspended for 
the period of time, prior to November 3, 1966, that collection is 
hindered or delayed because property of the taxpayer is situated or held 
outside the United States or is removed from the United States. The 
total suspension of time under this provision shall not in the aggregate 
exceed 6 years. In any case in which the district director determines 
that collection is so hindered or delayed, he shall make and retain in 
the files of his office a written report which shall identify the 
taxpayer and the tax liability, shall show what steps were taken to 
collect the tax liability, shall state the grounds for his determination 
that property of the taxpayer is situated or held outside, or is removed 
from, the United States, and shall show the date on which it was first 
determined that collection was so hindered or delayed.

[[Page 377]]

The term ``property'' includes all property or rights to property, real 
or personal, tangible or intangible, belonging to the taxpayer. The 
suspension of the running of the period of limitations on collection 
shall be considered to begin on the date so determined by the district 
director. A copy of the report shall be mailed to the taxpayer at his 
last known address. For further guidance regarding the definition of 
last known address, see Sec. 301.6212-2.

    (b) Taxpayer outside United States after November 2, 1966. The 
running of the period of limitations on collection after assessment 
prescribed in section 6502 (relating to collection after assessment) is 
suspended for the period after November 2, 1966, during which the 
taxpayer is absent from the United States if such period is a continuous 
period of absence from the United States extending for 6 months or more. 
In a case where the running of the period of limitations has been 
suspended under the first sentence of this paragraph and at the time of 
the taxpayer's return to the United States the period of limitations 
would expire before the expiration of 6 months from the date of his 
return, the period of limitations shall not expire until after 6 months 
from the date of the taxpayer's return. The taxpayer will be deemed to 
be absent from the United States for purposes of this section if he is 
generally and substantially absent from the United States, even though 
he makes casual temporary visits during the period.


[T.D. 7121, 36 FR 10782, June 3, 1971, as amended by T.D. 8939, 66 FR 
2821, Jan. 12, 2001]