Ezel / IRS Rulings / 1122019
Chief Counsel Advice 1122019 Released June 3, 2011 Advice

CCA 1122019: IRS advises sending a statutory notice only to the last known address

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This page covers one taxpayer's ruling from 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 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 states that IRC § 6213 requires the IRS to send a statutory notice to the taxpayer's last known address. In the circumstances discussed, the accounting firm was not the taxpayer's last known address. The advice therefore recommends not sending a copy to the firm because doing so could create a disclosure problem.

Ruling snapshot

  • Question: Should the IRS send a statutory notice to an accounting firm that is not the taxpayer's last known address?
  • Outcome: Advice.
  • Key authorities: IRC § 6213.

Full text (IRS public release)

ID: CCA_2011050417434047 Number: 201122019
Release Date: 6/3/2011
Office: --------------
UILC: 6212.02-00

From: ---------------------
Sent: Wednesday, May 04, 2011 5:43:49 PM
To: -------------------
Cc:
Subject: Last known address

Section 6213 only requires that we send the stat notice to the last known address. Based on our
conversation, the accounting firm is not a last known address, and we advise that you do not send a copy
to the firm, as that could be a disclosure problem.

Please let me know if you need anything further,

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