Rev. Rul. 78-245

Advice has been requested whether the period of limitations on assessment of the income tax return preparer penalties may be extended under section 6501(c)(4) of the Internal Revenue Code of 1954.

Section 6501(c)(4) of the Code provides for the extension by written consent of the time for assessment of any tax imposed by the Code (other than the estate tax provided in Chapter 11). Section 6659(a)(2) provides that any reference in the Code to "tax" imposed by the Code shall be deemed also to refer to the penalties provided by Chapter 68, in which all of the preparer penalties are located.

Accordingly, the period of limitations on assessment of the income tax return preparer penalties may be extended under section 6501(c)(4) of the Code.