Ezel / IRS Rulings / 201442055

Supplemental assessment uses deficiency procedures for deficiency tax

Number
201442055
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Supplemental Assessments
Topics
Procedure, penalties, and administration
Code sections
§ 6204, § 6211
Ruling dated
September 24, 2014
Publicly released
October 17, 2014
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 2014, 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 2014
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 advised that deficiency procedures apply to a supplemental assessment when the tax at issue is a deficiency tax within the meaning of § 6211. The brief email pointed to the cross-reference in § 6204(b).

Ruling snapshot

  • Question: Do deficiency procedures apply to the tax involved in a supplemental assessment?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6204(b) and 6211

Full text (IRS public release)

ID: CCA_2014092414492857 [Third Party Communication:

UILC: 6204.00-00 Date of Communication: Month DD, YYYY]

Number: 201442055
Release Date: 10/17/2014
From:
Sent: Wednesday, September 24, 2014 2:49:28 PM
To:
Cc:
Bcc:
Subject: RE: Code section 6204

I may not be understanding your question, but the deficiency procedures would apply if the tax at issue
was a deficiency tax per 6211. See the cross-reference in 6204(b).

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