Failure to File Certain Information Returns (See Also 6652.00-00)

ID:
UILC:
CCA_2014082213293528
6721.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201438028
Release Date: 9/19/2014
From:
Sent: Friday, August 22, 2014 1:29:35 PM
To:
Cc:
Bcc:
Subject: RE: Intentional Disregard Penalty Letter
Glad you sent this again, as I had overlooked it and didn’t realize that I had it on my plate.
The section 6721 penalty is assessable and the IRS does not need to follow deficiency procedures to assess it. The taxpayer would need to pay and bring a refund suit to challenge the penalty (unless the taxpayer uses CDP procedures).
So, assessing is an appropriate term in the letter.