Ezel / IRS Rulings / 200947043

CCA 200947043: Accrual of interest on an estimated-tax penalty

Number
200947043
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Interest on Underpayment, Nonpayment, or Extensions of Time for Payment of Tax (Interest v. No Interest Imposed)
Topics
Procedure, penalties, and administration
Code sections
§ 6601, § 6110
Publicly released
November 20, 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

This Chief Counsel advice addresses when interest on an estimated-tax penalty accrues. It states that interest begins on the date of notice and demand if the taxpayer does not pay within 21 days of notice and demand, or within 10 business days in certain cases. The advice cites IRC § 6601(e)(2)(A) and notes that the writer found no reason to reach a different conclusion.

Ruling snapshot

  • Question: When does interest accrue on an estimated-tax penalty after notice and demand?
  • Outcome: Advice given
  • Key authorities: IRC § 6601(e)(2)(A)

Full text (IRS public release)

ID: CCA_2009100714421242 Number: 200947043
Release Date: 11/20/2009
Office: ----------------------------
UILC: 6601.00-00

From: -------------------------
Sent: Wednesday, October 07, 2009 2:42:14 PM
To: ---------------------
Cc: -------------------
Subject: interest on penalty

As we previously discussed by phone, I think interest on an estimated tax penalty accrues from the date of notice and demand if a taxpayer fails to pay the amount within 21 days of notice and demand (or 10 business days in certain cases.) See I.R.C. § 6601(e)(2)(A). I haven't located anything that would lead me to believe otherwise.

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