Ezel / IRS Rulings / 201014057

CCA 201014057: IRS discusses frivolous collection due process requests

Number
201014057
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Collection Due Process - Levy
Topics
Procedure, penalties, and administration
Code sections
§ 6330
Ruling dated
March 4, 2010
Publicly released
April 9, 2010
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 2010, 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 2010
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 advice states that under section 6330(g), the IRS will deny a collection due process hearing request that contains only frivolous arguments if the taxpayer fails to file a proper amended request after receiving an opportunity to do so.

Ruling snapshot

  • Question: When may the IRS deny a collection due process hearing request containing only frivolous arguments?
  • Outcome: Advice given
  • Key authorities: IRC § 6330(g)

Full text (IRS public release)

ID: CCA_2010030409551455 Number: 201014057
Release Date: 4/9/2010
Office: ----------------------------
UILC: 6330.00-00

From: ---------------------
Sent: Thursday, March 04, 2010 9:55:16 AM
To: ----------------
Cc:
Subject: RE: Revised Outline

--------I took a quick look at this and it looks fine. In regards to frivolous submissions, I would also note that under section 6330(g) the IRS will deny a CDP hearing to a taxpayer if the hearing request contains only frivolous arguments and the taxpayer fails to file a proper amended hearing request after being given the opportunity to do so by the IRS.

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