Ezel / IRS Rulings / 201005049

CCA 201005049: An SS-10 should use the legal name on the return

Number
201005049
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
ADMINISTRATION
Topics
Income and deductions
Code sections
§ IRM 25.6.22.5.2
Ruling dated
January 13, 2010
Publicly released
February 5, 2010
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 2010, 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 2010
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 internal IRS Chief Counsel advice addresses which taxpayer name should appear on an SS-10 used to extend a limitations period. It states that the general rule is to use the name shown on the return for which the statute is being extended, which should be the legal name. The advice cites IRM 25.6.22.5.2.

Ruling snapshot

  • Question: Which name should be used on an SS-10 extending the statute for a return?
  • Outcome: Advice given.
  • Key authorities: IRM 25.6.22.5.2.

Full text (IRS public release)

ID: CCA_2010011308194047 Number: 201005049
Release Date: 2/5/2010
Office: ----------------------------
UILC: 01.00.00-00

From: ------------------------
Sent: Wednesday, January 13, 2010 8:19:48 AM
To: ----------------
Cc:
Subject: RE: Question

As stated in IRM 25.6.22.5.2, the general rule is that the SS-10 should use the name as stated on the
return for which the statute is being extended. That should be the legal name.

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