Ezel / IRS Rulings / 200940023

CCA 200940023: Patriot's Day can extend a filing deadline in limited situations

Number
200940023
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Time for Performance of Acts Where Last Day Falls on Saturday, Sunday, or Legal Holiday
Topics
Procedure, penalties, and administration
Code sections
§ 6091, § 7503
Ruling dated
August 13, 2009
Publicly released
October 2, 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

This Chief Counsel Advice addresses when the Patriot's Day holiday affects the time for filing a return. It states that the holiday applies only if the Service directed the taxpayer to submit the return to Andover for processing, or if the taxpayer hand-carried the return to an authorized recipient in a state where Patriot's Day is a statewide legal holiday. The advice cites sections 7503 and 6091 regulations for the deadline rule.

Ruling snapshot

  • Question: When does Patriot's Day extend the time for submitting a return?
  • Outcome: Advice given.
  • Key authorities: IRC § 7503; Treas. Reg. § 1.6091-2(d).

Full text (IRS public release)

ID: CCA_2009081312264954 Number: 200940023
Release Date: 10/2/2009
Office: --------------
UILC: 7503.00-00

From: --------------------------
Sent: Thursday, August 13, 2009 12:26:51 PM
To: --------------------
Cc: ---------------------------
Subject: RE: ACTION: Patriot Day Holiday

The Patriot's Day holiday would be applicable only if: the Service directed a taxpayer to submit a
return to Andover for processing; or, a taxpayer hand-carried a return to a person authorized to receive
hand-carried returns in a State where Patriot's Day is a Statewide legal holiday. I.R.C. § 7503; Treas.
Reg. § 1.6091-2(d).

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