Ezel / IRS Rulings / 200946045

CCA 200946045: Date formatting for consents extending the assessment period

Number
200946045
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Form and Contents of Waiver
Topics
Procedure, penalties, and administration
Code sections
§ 6501, § 6110
Ruling dated
September 25, 2009
Publicly released
November 13, 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 states that staff should stop using dates written only as numbers on consents extending the assessment period, but that a new consent is not required for the existing documents. It notes that day-first date formats used in some countries can create ambiguity and recommends spelling out months in future documents. The advice is administrative guidance about date formatting and does not decide a taxpayer-specific limitation period.

Ruling snapshot

  • Question: Should assessment-period consents use spelled-out months to avoid date ambiguity?
  • Outcome: Advice given
  • Key authorities: IRC § 6501

Full text (IRS public release)

ID: CCA_2009092515482844 Number: 200946045
Release Date: 11/13/2009
Office:
UILC: 6501.08-17

From: ----------------------------
Sent: Friday, September 25, 2009 3:48:53 PM
To: --------------------------
Cc: ------------------
Subject: Statute Extension ques - dates

The practice of using all numbers should not be continued, but, you don't need to get a new consent.

Some people (and the practice in some countries is to) write the day of the month followed by the month and then the year (DD/MM/YY) rather than MM/DD/YY. Since the 4 Form 941 quarters end on 3/31/06, 6/30/06, 9/30/06, and 12/31/06 - we shouldn't have a problem (e.g., because "31" in 12/31/06 could not be a month).

You should instruct your folks that the months (e.g., December 31, 2006) should always be spelled out in the future.

Thanks for the class.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace