CCA 200914061: A revised TEFRA settlement required a newly executed form

Plain-English summary

Chief Counsel responded to a question concerning a TEFRA settlement agreement. The response agreed with the proposed approach but advised obtaining an entirely new or revised executed form. It explained that a revised schedule could not simply be attached to a document the taxpayer had already signed. The brief email provides no additional facts about the settlement or the needed revision.

Ruling snapshot

• Question: How should the IRS document a revision to a TEFRA settlement form that the taxpayer had already signed?
• Outcome: Advice given: have the taxpayer execute an entirely new or revised form instead of attaching a revised schedule to the signed form.
• Key authorities: IRC § 6224.

Full text (IRS public release)

ID: CCA_2009030911015337 Number: 200914061
Release Date: 4/3/2009
Office: --------------
UILC: 6224.01-01

From: -------------------
Sent: Monday, March 09, 2009 11:01:54 AM
To: --------------------------
Cc: -----------
Subject: RE: TEFRA Q

I agree. But I would have them execute an entirely new/revised form. We can't attach a revised schedule to something the taxpayer has already signed.