Penalty in Lieu of Rebate

ID:
UILC:
CCA-08311055-15
148.09-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201539029
Release Date: 9/25/2015
From: ---
Sent: Monday, August 31, 2015 10:55 AM
To: ---
Cc: ---
Subject: Appeal of a denial of a waiver request of a section 148(f)(7) penalty
Several weeks ago --- asked whether a taxpayer has appeal rights if TEB denies a request under 5.02 of Rev. Proc. 2005-40 to waive the penalty imposed under section 148(f)(7). I asked PA for a response and received it Friday. After thoroughly reviewing the relevant authorities, PA concluded that a taxpayer cannot appeal TEB’s decision to not waive the penalty. If you have any questions please do not hesitate to call ------------