Ezel / IRS Rulings / 1040006
Chief Counsel Advice 1040006 Released October 8, 2010 Advice

CCA 1040006: Section 6662A did not appear to apply outside income tax or subtitle A

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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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