PUBLIC LAW 104-168—JULY 30, 1996 110 STAT. 1457 of a taxpayer with whom the Secretary has entered into an agreement xinder subsection (a) has significemtly changed, the Secretary may alter, modify, or terminate such agreement.", (c) EFFECTIVE DATE. —The amendments made by this section shall take effect on the date 6 months after the date of the enactment of this Act. SEC. 202. ADMINISTRATIVE REVIEW OF TERMINATION OF INSTALL- MENT AGREEMENT. (a) GENERAL RULE.— Section 6159 (relating to agreements for payment of tax liability in installments) is amended by adding at the end the following new subsection: "(c) ADMINISTRATIVE: REVIEW. — The Secretary shall establish procedures for an independent administrative review of terminations of installment agreements under this section for taxpayers who request such a review.". (b) EFFECTIVE DATE. —The amendment made by subsection (a) shall take effect on January 1, 1997. 26 USC 6159 note. 26 USC 6159 note. TITLE III—ABATEMENT OF INTEREST AND PENALTIES SEC. 301. EXPANSION OF AUTHORITY TO ABATE INTEREST. (a) GENERAL RULE.— Paragraph (1) of section 6404(e) (relating to abatement of interest in certain cases) is amended— (1) by inserting "unreasonable" before "error" each place it appears in subparagraphs (A) and (B), and (2) by striking "in performing a ministerial act" each place it appears and inserting "in performing a ministerial or managerial act". (b) CLERICAL AMENDMENT.—The subsection heading for subsection (e) of section 6404 is amended— (1) by striking "ASSESSMENTS" and inserting "ABATEMENT", and (2) by inserting "UNREASONABLE" before "ERRORS". (c) EFFECTIVE DATE. —The simendments made by this section shall apply to interest accruing with respect to deficiencies or pay- ments for taxable years beginning after the date of the enactment of this Act. SEC. 302. REVIEW OF IRS FAILURE TO ABATE INTEREST. (a) IN GENERAL.—Section 6404 is amended by adding at the end the following new subsection: "(g) REVIEW OF DENIAL OF REQUEST FOR ABATEMENT OF INTEREST. — "(1) IN GENERAL.— The Tax Court shall have jurisdiction over any action brought by a taxpayer who meets the requirements referred to in section 7430(c)(4)(A)(iii) to determine whether the Secretary failure to abate interest under this section was an abuse of discretion, and may order an abatement, if such action is brought within 180 days after the date of the mailing of the Secretsuys final determination not to abate such interest. "(2) SPECIAL RULES.— 26 USC 6404 note. Courts. ^plicability.
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