Ezel / IRS Rulings / 200848028

CCA 200848028: Form 872-I may combine section 6707A penalty language with a restricted consent

Number
200848028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Limitations on Assessment and Collection (Barred v. Not Barred)
Topics
Procedure, penalties, and administration
Code sections
§ 6501, § 6707A
Ruling dated
July 8, 2008
Publicly released
November 28, 2008
Source
View Official PDF

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This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2008, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2008
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advised that proposed language concerning the section 6707A penalty was acceptable for inclusion on Form 872-I. The same form could also contain the section 6707A language and a restricted consent, provided the consent met all other requirements in the cited Internal Revenue Manual provision. Counsel added that the restricted-consent language should be coordinated with the national office having jurisdiction over the subject.

Ruling snapshot

  • Question: May Form 872-I include section 6707A penalty language on the same form as a restricted consent?
  • Outcome: Advice given. The combined language is permissible if the restricted consent satisfies all other requirements.
  • Key authorities: IRC §§ 6501 and 6707A; IRM 25.6.22.8

Full text (IRS public release)

ID: CCA_2008070813351550 Number: 200848028
Office: --------------
Release Date: 11/28/2008

UILC: 6501.00-00

From: -----------------------
Sent: Tuesday, July 08, 2008 1:35:16 PM
To: --------------------
Cc: --------------------------------------------
Subject: FW: 872-I review

We are okay with the proposed section 6707A penalty language on the Form 872-I. We also don't see any problem including the section 6707A penalty language on the same form as the restricted consent as long as all of the other requirements for a restricted consent (discussed in IRM 25.6.22.8) are met. Note that the restricted consent language should be coordinated with the appropriate national office with jurisdiction over that subject matter. Please let us know if we can be of any further assistance. Thanks.

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