Ezel / IRS Rulings / 201122019

CCA 201122019: IRS advises sending a statutory notice only to the last known address

Number
201122019
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Name and Address
Topics
Procedure, penalties, and administration
Code sections
§ 6213
Ruling dated
May 4, 2011
Publicly released
June 3, 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 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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