Ezel / IRS Rulings / 200911026

CCA 200911026: A parent-company officer could sign the extension for a disregarded entity

Number
200911026
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Signing of Corporation Returns
Topics
Procedure, penalties, and administration
Code sections
§ 6062
Ruling dated
February 5, 2009
Publicly released
March 13, 2009
Source
View Official PDF

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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.

Currency note: this determination was released in 2009
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

Chief Counsel reviewed a proposed Form 872 involving a disregarded entity. It agreed with the submitted analysis about who could sign the consent to extend the limitations period. The signature of an officer of the parent company would suffice for the disregarded entity's consent.

Ruling snapshot

  • Question: Could an officer of a parent company sign a limitations-period extension for its disregarded entity?
  • Outcome: Advice given: yes, the parent's officer could provide a sufficient signature.
  • Key authorities: IRC § 6062; Form 872.

Full text (IRS public release)

ID: CCA_2009020515354243 Number: 200911026
Release Date: 3/13/2009
Office: --------------
UILC: 6062.00-00

From: --------------------
Sent: Thursday, February 05, 2009 3:35:43 PM
To: ------------------
Cc: -------------------------------------------
Subject: RE: -------------------- Proposed 872

We agree with your analysis that a signature of an officer of the parent will suffice for the consent to
extend the period of limitations for the disregarded entity.

Please let me know if there is anything else that you need.

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