Ezel / IRS Rulings / 201040006

CCA 201040006: Section 6662A did not appear to apply outside income tax or subtitle A

Number
201040006
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Accuracy Related Penalty on Understatements with respect to Reportable Transactions
Topics
Procedure, penalties, and administration
Code sections
§ 6662A
Ruling dated
September 1, 2010
Publicly released
October 8, 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 considered whether the section 6662A penalty applies to excise taxes. The advice stated that it did not see how section 6662A would apply to a tax outside income tax or subtitle A. The document does not provide further analysis of the issue.

Ruling snapshot

  • Question: Does IRC § 6662A apply to excise taxes or other taxes outside income tax or subtitle A?
  • Outcome: Advice given
  • Key authorities: IRC § 6662A

Full text (IRS public release)

ID: CCA_2010090113515364 Number: 201040006
Release Date: 10/8/2010
Office: --------------
UILC: 6662A.00-00

From: ------------------
Sent: Wednesday, September 01, 2010 1:51:55 PM
To: ---------------------
Cc:
Subject: RE: 6662A penalty for excise taxes

I don't see how 6662A applies to any tax outside of income tax or subtitle A.

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