CCA 200909061: Certain summonses suspend the assessment limitation period

Number

200909061

Outcome

Advice

Document type

Chief Counsel Advice

IRS subject

Voluntary Employees' Beneficiary Associations (See Also 0501.03-01)

Topics

Tax-exempt organizations

Code sections

§ 6501, § 6503

Ruling dated

January 5, 2009

Publicly released

February 27, 2009

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 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

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

In a heavily redacted email, Chief Counsel discussed how to handle an unspecified health and welfare matter involving an uncooperative taxpayer. The email identifies section 6503(j) as the provision that suspends the section 6501 assessment limitation period for certain summonses. It advises consulting another redacted person for more information and offers help coordinating with that person.

Ruling snapshot

Question: Which provision suspends the assessment limitation period in the case of certain summonses?
Outcome: Advice given: section 6503(j) provides the suspension.
Key authorities: IRC §§ 6501 and 6503(j).

Full text (IRS public release)

ID: CCA_2009010511544717 Number: 200909061
Release Date: 2/27/2009
Office: ------------------------
UILC: 501.09-00

From: --------------------------
Sent: Monday, January 05, 2009 11:54:55 AM
To: ----------------------
Cc: --------------------------------------
Subject: RE: 3401(d)(1) employer/Health and welfare issues

Dear -----

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--------------------------------------------------------------------------------------- ----------------do not have a preference and defer to you on how you would like to handle that, unless -------feels differently.

I followed up with ------------------on the section regarding uncooperative taxpayers. It is section 6503(j), which suspends the running of any period of limitations provided in section 6501 on assessment in the case of certain summonses. For any further information on the section, though, -------will have to be consulted. If you would like, we can help you coordinate with them. Happy new year!

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