Accuracy Related Penalty on Understatements with respect to Reportable Transactions

ID: CCA_2009081316372464 Number: 200939022
Release Date: 9/25/2009
Office: ---
UILC: 6662A.00-00
From: ---
Sent: Thursday, August 13, 2009 4:37:31 PM
To: ---
Cc: ---
Subject: RE: 6662A
Section 6662A is effective for tax years ending after 10/22/04, so it will not apply to the --- year. Note, however, that the 6662A penalty applies to understatements - an underpayment is not necessary. So, the fact that the loss was not used in --- does not necessarily mean that section 6662A does not apply to ---.