Ezel / IRS Rulings / 200943032

CCA 200943032: Storage expenses may qualify within the moving period

Number
200943032
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Moving Expenses (Deductible v. Not Deductible)
Topics
Income and deductions
Code sections
§ 217
Ruling dated
August 22, 2008
Publicly released
October 23, 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 responds to a question about whether storage expenses qualify as moving expenses. The writer says the facts are incomplete but identifies storage as an important factor in the scenario presented. The advice quotes IRS Publication 521 for the rule that the cost of storing and insuring household goods and personal effects may be included for any period of 30 consecutive days after the belongings are moved from the former home and before delivery to the new home.

Ruling snapshot

  • Question: When may storage and insurance costs for household goods be included as moving expenses?
  • Outcome: Advice given
  • Key authorities: IRC § 217; IRS Publication 521

Full text (IRS public release)

ID: CCA-822114-08 Number: 200943032
Release Date: 10/23/2009
Office: ----------------
UILC: 217.00-00

From: ---------------------
Sent: Friday, August 22, 2008 11:29 AM
To: -----------------
Subject: RE: Moving Expenses

---------
I do not feel like I have all the facts but there are certainly enough to agree with your nevousness regarding the storage expenses. It seems, in the senerio you gave, that the storage was a key factor in the underlying facts. However, I think the following paragraph from page 8 of Pub. 521 is incitful:

Storage Expenses. You can include the cost of storing and insuring household goods and personal effects within any period of 30 consecutive days after the day your things are moved from your former home and before they are delivered to your new home.

Good luck-- -----------------------------

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