CCA 1315025: Remailing a notice to a requested address

Plain-English summary

Chief Counsel advice considers how the Service should handle a notice that was sent to the taxpayer's last known address and later needs to be remailed to another requested address. Assuming the original address was the taxpayer's last known address, the advice says the Service should send a copy to the requested address. The copy should retain the original mailing date. The memo cites an Internal Revenue Manual procedure concerning undeliverable notices of deficiency as an example of the practice.

Ruling snapshot

• Question: How should a notice be remailed when the original notice went to the taxpayer's last known address?
• Outcome: Advice given, re-mail a copy using the original mailing date.
• Key authorities: IRC § 6212; IRM 4.19.21.2(9).

Full text (IRS public release)

ID: CCA_2013031410480103 Number: 201315025
Release Date: 4/12/2013
Office: --------------
UILC: 6212.02-04

From: --------------------
Sent: Thursday, March 14, 2013 10:48:05 AM
To: --------------------
Cc:
Subject: RE: last known address question

Assuming that the address that the Service sent the original notice to was that taxpayer’s last
known address, then a copy should be remailed (with the original mailing date) to the taxpayer at
the requested address. See e.g. IRM 4.19.21.2(9) (05-29-2012) Processing Incoming Correspondence
(discussing procedures for remailing undeliverable notices of deficiency). Let me know if you have any
other questions.