Ezel / IRS Rulings / 200848037

CCA 200848037: No statutory right to Appeals consideration

Number
200848037
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Privilege to File Consolidated Returns (May v. May Not File Consolidated Return)
Topics
Corporate transactions and reorganizations
Code sections
§ 1501
Ruling dated
July 14, 2008
Publicly released
November 28, 2008
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2008, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2008
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

The subject line refers to a 60-day objection letter, but the released email does not include the question. Chief Counsel answered yes and stated that there is no statutory right to Appeals consideration. No further facts, conditions, or legal analysis appear in the release.

Ruling snapshot

  • Question: The precise question concerning the 60-day objection letter is not included in the released text.
  • Outcome: Advice given. There is no statutory right to Appeals consideration.
  • Key authorities: No authority is cited in the released email.

Full text (IRS public release)

1

ID: CCA-714147-08 Number: 200848037
Office: --------------
Release Date: 11/28/2008

UILC: 1501-00-00

From: -------------------
Sent: Mon 7/14/2008 2:47 PM
To: -------------------------
Cc: -------------------------------------------------------------------------------------------------------------------
Subject: RE: 60 Day Objection letter

Yes. There is no statutory right to appeals consideration.

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