Ezel / IRS Rulings / 201113033

CCA 201113033: Bankruptcy need not be addressed in a notice of deficiency

Number
201113033
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Notice of Deficiency
Topics
Procedure, penalties, and administration
Code sections
§ 6212
Ruling dated
February 25, 2011
Publicly released
April 1, 2011
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 2011, 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 2011
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 addressed whether a notice of deficiency must discuss the effect of a taxpayer's bankruptcy. The advice stated that there is no legal requirement to address bankruptcy in the body of the notice of deficiency. The short email concerned the notice process under IRC § 6212.

Ruling snapshot

  • Question: Must a notice of deficiency address the effect of bankruptcy?
  • Outcome: Advice given, no legal requirement was identified.
  • Key authorities: IRC § 6212.

Full text (IRS public release)

ID: CCA_2011022515151450 Number: 201113033
Release Date: 4/1/2011
Office: ----------
UILC: 6212.00-00

From: -----------------------
Sent: Friday, February 25, 2011 3:15:18 PM
To: ---------------------
Cc:
Subject: RE: Letter 1384 revision

There is no legal requirement to address the effect of bankruptcy in the body of the
notice of deficiency. -----------------------------------------------------------------------------------------
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