Ezel / IRS Rulings / 1221018
Chief Counsel Advice 1221018 Released May 25, 2012 Advice

CCA 1221018: Chief Counsel addresses reporting interest on unclaimed funds

Apply this to your situation

This page covers one taxpayer's ruling from 2012, 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 2012
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 addressed how a state office should report interest paid on unclaimed funds under IRC § 6049. The advice said that, assuming a reporting obligation exists, the interest should be reported using the name and taxpayer identification number of the decedent or the decedent's estate, depending on who would include the interest in income. It further stated that a Form 1099-INT should generally use the decedent's name and Social Security number when the interest belongs on the decedent's final return, and the estate's number when the interest is income to the estate.

Ruling snapshot

  • Question: Which payee name and taxpayer identification number should be used when reporting interest on unclaimed funds paid after a person's death?
  • Outcome: Advice given
  • Key authorities: IRC § 6049

Full text (IRS public release)

ID: CCA_2012043013382818 Number: 201221018
Release Date: 5/25/2012
Office: -------------
UILC: 6049.00-00

From: --------------------
Sent: Monday, April 30, 2012 1:38:29 PM
To: -------------------
Cc:
Subject: RE: Section 6049

As we discussed this morning, I ran the issue past another attorney in the branch who is considerably
more knowledgeable about information returns and reporting requirements than I am. Essentially, the
state office should report (assuming it has a reporting obligation under section 6049) the interest paid on
the unclaimed funds using the name and TIN of the decedent or the decedent's estate, as appropriate.
Without regard to payment on a claim by a nursing home or funeral home for services rendered, if the
interest being reported is or would be includible on the decedent's final income tax return, then
presumably the Form 1099-INT should report the decedent's name and SSN, whereas the estate's
number (if there is one) should be used if the interest is income to the estate. In other words, the
reporting, in terms of payee name and TIN, seemingly should operate the same as if the funds were held
in a bank account. Let me know if you want to discuss or have questions. Thanks.

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2012, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.