Ezel / IRS Rulings / 200948052

CCA 200948052: A valuation-misstatement penalty applies only to the attributable underpayment

Number
200948052
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Accuracy-related penalty
Topics
Procedure, penalties, and administration
Code sections
§ 6662, § 6110
Publicly released
November 27, 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 an accuracy-related penalty under IRC § 6662. It cites LGM TL-68 (rev.) and states that § 6662(b) applies the penalty only to the portion of an underpayment attributable to a valuation misstatement.

Ruling snapshot

  • Question: To what portion of an underpayment does the valuation-misstatement penalty apply?
  • Outcome: Advice given
  • Key authorities: IRC § 6662(b); LGM TL-68 (rev.)

Full text (IRS public release)

ID: CCA_2009102609582764 Number: 200948052
Release Date: 11/27/2009
Office: --------------
UILC: 6662.00-00

From: ------------------
Sent: Monday, October 26, 2009 9:58:37 AM
To: --------------------
Cc:
Subject: RE: [ --------- ] case and 6662(h) penalty

LGM TL-68 (rev.). Also, section 6662(b) says that the penalty applies only to that portion of an
underpayment that is "attributable to … a valuation misstatement."

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