'"?^':-^- PUBLIC LAW 105-206-^JULY 22, 1998 112 STAT. 741 of the existence thereof is furnished in such form and manner as the Secretary may require. "(B) EXCEPTION WHERE INDIVIDUAL HAS GUARDIAN, ETC.— An individual shall not be treated as financially disabled during any period that such individual's spouse or any other person is authorized to act on behalf of such individual in financial matters.". (b) EFFECTIVE DATE. —The amendment made by subsection (a) shall apply to periods of disability before, on, or after the date of the enactment of this Act but shall not apply to any claim for credit or refund which (without regard to such amendment) is barred by the operation of any law or rule of law (including res judicata) as of the date of the enactment of this Act. Subtitle D—Provisions Relating to Interest and Penalties Applicability. 26 USC 6511 note. SEC. 3301. ELIMINATION OF INTEREST RATE DIFFERENTIAL ON OVER- LAPPING PERIODS OF INTEREST ON TAX OVERPAY- MENTS AND UNDERPAYMENTS. (a) IN GENERAL.—Section 6621 (relating to determination of rate of interest) is amended by adding at the end the following new subsection: "(d) ELIMINATION OF INTEREST ON OVERLAPPING PERIODS OF TAX OVERPAYMENTS AND UNDERPAYMENTS.—TO the extent that, for any period, interest is payable under subchapter A and allowable under subchapter B on equivalent underpayments and overpay- ments by the same taxpayer of tax imposed by this title, the net rate of interest under this section on such amounts shall be zero for such period.". (b) CONFORMING AMENDMENT. —Subsection (f) of section 6601 (relating to satisfaction by credits) is amended by adding at the end the following new sentence: "The preceding sentence shall not apply to the extent that section 6621(d) applies.". (c) EFFECTIVE DATES. — (1) IN GENERAL. — Except as provided under paragraph (2), the amendments made by this section shall apply to interest for periods beginning after the date of the enactment of this Act. (2) SPECIAL RULE. —The amendments made by this section shall apply to interest for periods beginning before the date of the enactment of this Act if the taxpayer— (A) reasonably identifies and establishes periods of such tax overpayments and underpayments for which the zero rate applies; and (B) not later than December 31, 1999, requests the Deadline. Secretary of the Treasury to apply section 6621(d) of the Internal Revenue Code of 1986, as added by subsection (a), to such periods. SEC. 3302. INCREASE IN OVERPAYMENT RATE PAYABLE TO TAXPAYERS OTHER THAN CORPORATIONS. (a) IN GENERAL. —Subparagraph (B) of section 6621(a)(1) (defining overpayment rate) is amended to read as follows: "(B) 3 percentage points (2 percentage points in the case of a corporation).". Applicability. 26 USC 6601 note.
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