Ezel / IRS Rulings / 201513002

Generic correspondence is not subject to the section 6702 penalty

Number
201513002
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
What Constitutes
Topics
Procedure, penalties, and administration
Code sections
§ 6702
Ruling dated
September 9, 2014
Publicly released
March 27, 2015
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 2015, 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 2015
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 was asked for legal advice about the section 6702 penalty. The response explained that the Code identifies the kinds of documents subject to that penalty. It advised that generic correspondence is not one of them.

Ruling snapshot

  • Question: Is generic correspondence a document subject to the section 6702 penalty?
  • Outcome: Advice given, generic correspondence is not subject to the penalty
  • Key authorities: IRC § 6702

Full text (IRS public release)

ID: CCA-992014-14 [Third Party Communication:

UILC: 6702.01-00 Date of Communication: Month DD, YYYY]

Number: 201513002
Release Date: 3/27/2015
From: ---------------------------------------------------------------------------
Sent: September 9, 2014 17:11 PM
To: ---------------------------------------------------------------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
---------------------------------------------------
Bcc:
Subject: RE: Request for Legal Advice from SB

Gordon, the code is specific about what kinds of documents are subject to the
penalty. Generic correspondence is not.

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