Acquiescence to the holding that the term “taxpayer” in section 7811 can be broadly interpreted to include a wrongful-levy claimant. Nonacquiescence to the holding that section 7811(d) suspends the running of the limitations periods for third-parties to file wrongful levy claims or suits.

This notice provides a waiver of additions to tax for failure to make a deposit of taxes for employers required to pay qualified sick leave wages and qualified family leave wages mandated by the Families First Coronavirus Response Act (Families First Act) and qualified health plan expenses allocable to these wages. This notice also provides a waiver of additions to tax for failure to make a deposit of taxes for certain employers experiencing a full or partial business suspension due to orders from a governmental authority due to the coronavirus disease 2019 or experiencing a statutorily specified decline in business under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). This notice applies to deposits of Employment Taxes (including withheld income taxes, taxes under the Federal Insurance Contributions Act and taxes under the Railroad Retirement Act) reduced in anticipation of the credits with respect to qualified sick leave wages and qualified family leave wages paid with respect to the period beginning April 1, 2020, and ending December 31, 2020. This notice applies with respect to deposits of Employment Taxes reduced in anticipation of the credits with respect to qualified wages paid with respect to the period beginning on March 13, 2020, and ending December 31, 2020.

Announcement 2020-4 provides that public hearings on notices of proposed rulemaking will be held telephonically and encourages taxpayers to submit public comments electronically.

The proposed regulations provide guidance on determining life insurance reserves and changing the method of computing certain insurance company reserves. The proposed regulations also authorize changes to insurance company reporting requirements and propose numerous conforming changes to other regulations. The proposed regulations implement legislative changes made by sections 13513 and 13517 of the Tax Cuts and Jobs Act.