112 STAT. 770 PUBLIC LAW 105-206—JULY 22, 1998 "(2) the taxpayer (and, if such liabiHty relates to a joint return, the taxpayer's spouse) has not, during any of the preceding 5 taxable years— "(A) failed to file any return of tax imposed by subtitle A; "(B) failed to pay any tax required to be shown on any such return; or "(C) entered into an installment agreement under this section for payment of any tax imposed by subtitle A, "(3) the Secretary determines that the taxpayer is financially unable to pay such liability in full when due (and the taxpayer submits such information as the Secretary may require to make such determination); "(4) the agreement requires full payment of such liability within 3 years; and "(5) the taxpayer agrees to comply with the provisions of this title for the period such agreement is in effect.". 26 USC 6159 (b) EFFECTIVE DATE.— The amendment made by this section °ote. shall take effect on the date of the enactment of this Act. 26 USC 7421 SEC. 3468. PROHIBITION ON REQUESTS TO TAXPAYERS TO GIVE UP note. RIGHTS TO BRING ACTIONS. (a) PROHIBITION.—No officer or employee of the United States may request a taxpayer to waive the taxpayer's right to bring a civil action against the United States or any officer or employee of the United States for any action taken in connection with the internal revenue laws. (b) EXCEPTIONS.— Subsection (a) shall not apply in any case where— (1) a taxpayer waives the right described in subsection (a) knowingly and voluntarily; or (2) the request by the officer or employee is made in person and the taxpayer's attorney or other federally authorized tax practitioner (within the meaning of section 7525(a)(3)(A) of the Internal Revenue Code of 1986) is present, or the request is made in writing to the taxpayer's attorney or other representative. Subtitle F—Disclosures to Taxpayers Procedures. 26 USC 7801 note. Deadline. 26 USC 7801 note. Deadline. SEC. 3501. EXPLANATION OF JOINT AND SEVERAL LIABILITY. (a) IN GENERAL. —The Secretary of the Treasury or the Secretary delegate shall, as soon as practicable, but not later than 180 days after the date of the enactment of this Act, establish procedures to clearly alert married taxpayers of their joint and several liabilities on all appropriate publications and instructions. (b) RIGHT TO LIMIT LIABILITY. — The procedures under subsection (a) shall include requirements that notice of an individual's right to relief under section 6015 of the Internal Revenue Code of 1986 shall be included in the statement required by section 6227 of the Omnibus Taxpayer Bill of Rights (Internal Revenue Service Publication No. 1) and in any collection-related notices. SEC. 3502. EXPLANATION OF TAXPAYERS' RIGHTS IN INTERVIEWS WITH THE INTERNAL REVENUE SERVICE. The Secretary of the Treasury or the Secretary's delegate shall, as soon as practicable, but not later than 180 days after the date
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