Ezel / IRS Rulings / 201114023

CCA 201114023: A return showing no tax decrease may call for the minimum penalty

Number
201114023
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Penalty for Failure to Include Reportable Transaction Information with Return
Topics
Procedure, penalties, and administration
Code sections
§ 6707A
Ruling dated
February 28, 2011
Publicly released
April 8, 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 considered the amount of a penalty under IRC § 6707A when a return shows no decrease in tax. The advice stated that, in that situation, it did not see how the penalty could be imposed in an amount other than the minimum. The short advice addresses the penalty floor when the return does not show a tax reduction.

Ruling snapshot

  • Question: What amount of the section 6707A penalty applies when a return shows no decrease in tax?
  • Outcome: Advice given.
  • Key authorities: IRC § 6707A.

Full text (IRS public release)

ID: CCA_2011022813135264 Number: 201114023
Release Date: 4/8/2011
Office: --------------
UILC: 6707A.00-00

From: ------------------
Sent: Monday, February 28, 2011 1:13:54 PM
To: ------------------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
-----------------------------------------------------------------------
Subject: FW: 6707A calculation request

When there is no decrease in tax shown on a return, I don't see how we could impose a penalty other
than in the minimum amount.

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