Erroneous claim for refund or credit

ID:
UILC:
CCA_2019111509251413
6501.00-00, 6676.00-00
Number: 202044007
Release Date: 10/30/2020
From:
Sent: Friday, November 15, 2019 9:25:14 AM
To:
Cc:
Bcc:
Subject: Question about statute of limitations and section 6676 penalty
This advice responds to your request for assistance.
Issue: Whether the statute of limitations bars assessment of the section 6676 penalty in the following situation.
Facts: More than three years ago, a taxpayer filed an income tax return claiming a substantial amount of false withholdings, resulting in an erroneous refund for which a section 6676 penalty is warranted. The claiming of the withholdings has been shown to be fraudulent.
Conclusion: The statute of limitations does not bar assessment of the section 6676 penalty in this situation.
Please let us know if you have any follow-up questions.