Ezel / IRS Rulings / 200952055

CCA 200952055: A new TAM could be submitted for rehearing

Number
200952055
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Transfers for Public, Charitable, and Religious Uses(Deductible v. Not Deductible)
Topics
Estate tax
Code sections
§ 2055
Ruling dated
December 1, 2009
Publicly released
December 25, 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 Advice explains that a new Technical Advice Memorandum could be submitted for a rehearing in a redacted matter. The advice directs the sender to submit the new TAM through the relevant Counsel's office for review.

Ruling snapshot

  • Question: Could a new TAM be submitted for rehearing in the matter?
  • Outcome: Advice given
  • Key authorities: IRC § 2055

Full text (IRS public release)

ID: CCA_2009120111015765 Number: 200952055
Release Date: 12/24/2009
Office: ----------------
UILC: 2055.00-00

From: ---------------------
Sent: Tuesday, December 01, 2009 11:01:58 AM
To: -----------------------
Cc:
Subject: TAM

------------

Did you get my messages from a few weeks ago regarding submitting a new TAM?

You can submit a new TAM for a rehearing in the ------------ matter in a similar way to submission of a
brand new TAM. Send the TAM through the -------------- Counsel's office and then they'll submit the TAM
to us for our review.

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