89OTest cases

1. This section applies if—

2. a dispute between a disputant and the Commissioner has been identified; and
3. the Commissioner has designated a separate challenge as a test case.

4. The disputant and the Commissioner may agree, recording their agreement in a document, to suspend the proceedings in the dispute because there is significant similarity between the facts and questions of law in the dispute and the facts and questions of law in the challenge that has been designated as a test case.

5. A suspension that is agreed under subsection (2) starts on the date of the agreement and ends on the earliest of—

6. the date of the court's decision in the test case:
7. the date on which the test case is otherwise resolved:
8. the date on which the dispute is otherwise resolved.

9. The Commissioner may make an assessment or perform an action in relation to a suspended dispute that is consistent with the resolution of the test case.

10. The Commissioner must make an amended assessment, or perform an action, that is the subject of a suspended dispute by the later of the following:

11. the day that is 60 days after the last day of the suspension:
12. the last day of the period that—
    1. begins on the day following the day by which the Commissioner, in the absence of the suspension, would be required under the Inland Revenue Acts to make the amended assessment, or perform the action; and
    2. contains the same number of days as does the period of the suspension.