Section 51.9 - Tax treatment of fee(a)Treatment as an excise tax. The fee imposed by section 9008 is treated as an excise tax for purposes of subtitle F of the Internal Revenue Code (Code) (sections 6001-7874). Thus, references in subtitle F to "taxes imposed by this title," "internal revenue tax," and similar references, are also references to the fee imposed by section 9008. For example, the fee imposed by section 9008 is assessed (section 6201), collected (sections 6301, 6321, and 6331), enforced (section 7402 and 7403), subject to examination and summons (section 7602), and subject to confidentiality rules (section 6103) in the same manner as taxes imposed by the Code.(b)Deficiency procedures. The deficiency procedures of sections 6211-6216 do not apply to the fee imposed by section 9008.(c)Limitation on assessment. The IRS must assess the amount of the fee for any fee year within three years of September 30th of that fee year.(d)Application of section 275. The fee is treated as a tax described in section 275(a)(6) (relating to taxes for which no deduction is allowed).T.D. 9684, 79 FR 43645 , July 28, 2014