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Ezel / IRS Rulings / 201650015
Chief Counsel Advice 201650015 Released December 9, 2016 Advice

Accuracy penalty belongs in computational adjustment notice

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This page covers one taxpayer's ruling from 2016, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2016
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 addressed where an accuracy-related penalty should appear when coordinating affected-item and deficiency procedures. It advised that the penalty should not be included in the statutory notice of deficiency because section 6230(a)(2) removes it from deficiency procedures. The penalty could properly be included in the notice of computational adjustment. The email provides no further factual detail.

Ruling snapshot

  • Question: Should the accuracy-related penalty appear in the statutory notice of deficiency or the computational adjustment notice?
  • Outcome: advice given
  • Key authorities: IRC § 6230(a)(2)

Full text (IRS public release)

ID: CCA_2016092808375507
UILC: 6230.01-00

Number: 201650015
Release Date: 12/9/2016
From:
Sent: Wednesday, September 28, 2016 8:37:56 AM
To:
Cc:
Bcc:
Subject: RE: Affected Item SNOD - accuracy-related penalty

--------,

The accuracy-related penalties should NOT be in the SND. They are NOT subject to
deficiency procedures. I.R.C. 6230(a)(2). Yes, it is proper in the notice of computational
adjustment.

Thanks,

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