Limitations on Assessment and Collection (Barred v. Not Barred)

ID: CCA_2009020208362164 Number: 200911016
Release Date: 3/13/2009
Office: ---
UILC: 6501.00-00/6707A.01-01
From: ---
Sent: Monday, February 02, 2009 8:36:23 AM
To: ---
Cc: ---
Subject: RE: Assessment of 6707A penalty
I don't recall the issue coming up before.
Where the disclosure was supposed to occur with a return for a particular tax year, I believe the penalty should be assessed for the tax year of the return the disclosure should have been made with. In your example, that would be ---. I think this is best because we view the SOL on assessments as running from the filing of the return with which a disclosure should have been made (when disclosure is required with a return).