Ezel / IRS Rulings / 200931047

CCA 200931047: Letter addressing a scrivener's error is appropriate under the inspection rule

Number
200931047
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Restrictions on Examination of Taxpayer
Topics
Procedure, penalties, and administration
Code sections
§ 7605
Publicly released
July 31, 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 considered whether a letter addressing a scrivener's error was appropriate. The advice states that IRC § 7605(b) generally permits only one inspection of a taxpayer's books of account. It also notes that an additional inspection is permitted when the Secretary notifies the taxpayer in writing that it is necessary.

Ruling snapshot

  • Question: Is the letter addressing a scrivener's error appropriate under IRC § 7605(b)?
  • Outcome: Advice given
  • Key authorities: IRC § 7605(b)

Full text (IRS public release)

ID: CCA-715844-08 Number: 200931047
Office: --------------
Release Date: 7/31/2009

UILC: 7605.01-00

From:--------------------
Sent: Tue 7/15/2008 8:44 AM
To:---------------------
Cc:--------------------------------------------------------------------------------------------------------------------
Subject: FW: Scrivener's Error

I think the letter is appropriate. Section 7605(b) provides that "only one
inspection of a taxpayer's books
of account shall be made . . . unless the Secretary . . . notifies the taxpayer in writing that an additional
inspection is necessary."

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