Settlement of Penalties

ID:
UILC:
CCA_2015072414212118
6224.01-02
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201534011
Release Date: 8/21/2015
From:
Sent: Friday, July 24, 2015 2:21:21 PM
To:
Cc:
Bcc:
Subject: RE: tefra question
That must have been his analysis then. Section 6224(c) does not extend rights to consistent settlement with respect to penalties where the settlement is based on partner-level defenses/matters. See Treas Reg 301.6224(c)-3(b).
Happy to discuss further if necessary.