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Chief Counsel Advice 202139008 Released October 1, 2021 Advice

Statutory overpayment-interest limits apply in the savings-bond context

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This page covers one taxpayer's ruling from 2021, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

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 interest in connection with the purchase of U.S. Series I savings bonds through Form 8888. The brief email states that, in the bond context, the listed provisions of Section 6611 apply when their conditions are met. Those provisions would prohibit or limit payment of interest as described in the statute. The released text does not provide further facts or analysis.

Ruling snapshot

  • Question: Do specified Section 6611 limits on interest payments apply in the savings-bond context?
  • Outcome: Advice given, the provisions prohibit or limit interest when applicable
  • Key authorities: IRC § 6611(b)(3), (e)(1), (e)(3), and (g)

Full text (IRS public release)

ID:      CCA_2021080609590950
UILC:    103.00-00

Number: 202139008
Release Date: 10/1/2021
From: ---------------------
Sent: Friday, August 6, 2021 9:59:09 AM
To: --------------------
Cc:
Bcc:
Subject: RE: Form 8888 & Interest on Purchase of U.S. Series I Savings Bonds


[-------and I are in agreement that in the bond context, when these provisions
[6611(b)(3), (e)(1), (e)(3), and (g)] are applicable, they would prohibit or limit payment of
interest as described in the statute
]

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