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

ID:
UILC:
CCA_2015092412380047
6721.00-00
Number: 201549026
Release Date: 12/4/2015
From:
Sent: Thursday, September 24, 2015 12:38:00 PM
To:
Cc:
Bcc:
Subject: RE: Pub. 1
Pub 1 is required for Form 8300 examinations because “the determination or collection of any tax” as used in the statute includes penalties under sections 6721 & 6722 for failing to file Forms 8300, as these penalties are assessable penalties that are treated as a tax. See section 6671.
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