Ezel / IRS Rulings / 200914031

CCA 200914031: Only a current officer could sign a consent for a state-law entity

Number
200914031
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229
Ruling dated
October 23, 2008
Publicly released
April 3, 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.

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 answered a question about who could sign a limitations-period consent for an entity created under state law. It advised that only a current officer could sign for the entity. Nearly all of the explanation preceding that conclusion was redacted from the public release. The email therefore does not reveal the proposed signer or any additional circumstances.

Ruling snapshot

  • Question: Who could sign a limitations-period consent for a state-law entity?
  • Outcome: Advice given: only a current officer could sign for the entity.
  • Key authorities: IRC § 6229.

Full text (IRS public release)

ID: CCA-310127-09 Number: 200914031
Office: --------------
Release Date: 4/3/2009

UILC: 6229.02-00

From: -------------------
Sent: Thu 10/23/2008 10:23 AM
To: --------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
-----------------------
Subject: RE: Consent ---------

-----------------------------------------------------------------------------
-------------------------------------------------- Only a current officer
can sign for a state law entity.

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