Ezel / IRS Rulings / 201442055
Chief Counsel Advice 201442055 Released October 17, 2014 Advice

Supplemental assessment uses deficiency procedures for deficiency tax

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This page covers one taxpayer's ruling from 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 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 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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