Ezel / IRS Rulings / 200944029

CCA 200944029: A timely computational adjustment remains valid after an invalid notice

Number
200944029
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Effect of Failure to Notify
Topics
Procedure, penalties, and administration
Code sections
§ 6222
Ruling dated
August 21, 2009
Publicly released
October 30, 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 a directly assessable computational adjustment in the appropriate amount. It states that a timely assessment remains valid even if an invalid statutory notice was issued beforehand. The Advice therefore concludes that the assessment should not be abated and reassessed.

Ruling snapshot

  • Question: Is a timely computational adjustment valid when it was preceded by an invalid statutory notice?
  • Outcome: Advice given
  • Key authorities: IRC § 6222

Full text (IRS public release)

ID: CCA_2009082110320537 Number: 200944029
Release Date: 10/30/2009
Office: --------------
UILC: 6222.03-00

From: -------------------
Sent: Friday, August 21, 2009 10:32:06 AM
To: --------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------
Subject: RE: K-1 Discrepancies

A timely assessment of a directly assessable computational adjustment in the appropriate amount will be
valid even if predated by an invalid stat notice. So it should not be abated and reassessed.

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