Ezel / IRS Rulings / 200923037

CCA 200923037: Interest on agreed employment taxes starts on agreement date if unpaid

Number
200923037
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Special Rules Applicable to Certain Employment Taxes
Topics
Procedure, penalties, and administration
Code sections
§ 6205
Ruling dated
August 4, 2008
Publicly released
June 5, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, 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 2009
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 confirmed the interest treatment for agreed employment tax liabilities in non-worker-classification or section 530 cases. If the taxpayer agrees to the liability but does not pay it, interest begins on the agreement date. The period from the original date through the agreement date remains interest-free. The email says a revised letter incorporating the changes would follow.

Ruling snapshot

  • Question: When does interest begin if a taxpayer agrees to an employment tax liability but does not pay it?
  • Outcome: Advice given, interest begins on the agreement date
  • Key authorities: IRC § 6205

Full text (IRS public release)

ID: CCA_2008080417205841 Number: 200923037
Release Date: 6/5/2009
Office: -----------------------------
UILC: 6205.00-00

From: ---------------
Sent: Monday, August 04, 2008 5:20:59 PM
To: ----------------------------------------------
Cc: --------------------------------------------------------
Subject: RE: Review and Comment on new Appeals Employment Tax Non-Worker Classification/Section
530 Cases

To confirm, if they agree but don't pay, interest just starts from the date of the agreement; they still get
interest-free back from original date to point of agreement. Will send revised letter with changes shortly
(assuming 2009 for beginning use).

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace