806
INTERNAL REVENUE CODE OF 1954
taxable corporation for the taxable year for which the return is filed, such return shall be deemed the return of the corporation for purposes of this section, (h) JOINT INCOME RETURN A F T E R SEPARATE "RETURN.— For period of limitations for assessment and collection in the case of a joint income return filed after separate returns have been filed, see section 6013(b)(3) and (4). SEC. 6502. COLLECTION AFTER ASSESSMENT. (a) L E N G T H OF PERIOD.—Where the assessment of any tax imposed
by this title has been made within the period of limitation properly applicable thereto, such tax may be collected by levy or by a proceeding in court, but only if the levy is made or the proceeding begun— (1) within 6 years after the assessment of the tax, or (2) prior to the expiration of any period for collection agreed upon in writing by the Secretary or his delegate and the taxpayer before the expiration of such 6-year period (or, if there is a release of levy under section 6343 after such 6-year period, then before such release). The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon. (b) D A T E W H E N LEVY I S CONSIDERED M A D E. — The date on which a levy on property or rights to property is made shall be the date on which the notice of seizure provided in section 6335(a) is given. SEC. 6503. SUSPENSION OF RUNNING OF PERIOD OF LIMITATION. (a) ISSUANCE OF STATUTORY NOTICE OF D E F I C I E N C Y. — (1) GENERAL RULE.—The running of the period of limitations
provided in section 6501 or 6502 on the making of assessments or the collection by levy or a proceeding in court, in respect of any deficiency as defined in section 6211 (relating to income, estate, and gift taxes), shall (after the mailing of a notice under section 6212(a)) be suspended for the period during which the Secretary or his delegate is prohibited from making the assessment or from collecting by levy or a proceeding in court (and in any event, if a proceeding in respect of the deficiency is placed on the docket of the Tax Court, until the decision of the Tax Court becomes final), and for 60 days thereafter. (2) CORPORATION JOINING IN CONSOLIDATED INCOME TAX R E -
TURN.—If a notice under section 6212(a) in respect of a deficiency in tax imposed by subtitle A for any taxable year is mailed to a corporation, the suspension of the running of the period of limitations provided in paragraph (1) of this subsection shall apply in the case of corporations with which such corporation made a consolidated income tax return for such taxable year. (b) ASSETS OF TAXPAYER IN CONTROL OR CUSTODY OF C O U R T. —
The period of limitations on collection after assessment prescribed in section 6502 shall be suspended for the period the assets of the taxpayer (other than the estate of a decedent or of an incompetent) are in the control or custody of the court in any proceeding before any court of the United States or of any State or Territory or of the District of Columbia, and for 6 months thereafter. (c) LOCATION OF PROPERTY OUTSIDE THE UNITED STATES OR REMOVAL OF PROPERTY F R O M THE UNITED STATES.—In case collection § 6501(g)(2)
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