Ezel / IRS Rulings / 201008036

CCA 201008036: Service offices should follow Chief Counsel Notice 2009-011

Number
201008036
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Coordination with Deficiency Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6230
Ruling dated
January 15, 2010
Publicly released
February 26, 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

Chief Counsel advised that Counsel maintains the position set forth in Chief Counsel Notice 2009-011. The Service should continue to adhere to the recommendations in that notice. The short CCA addresses coordination with deficiency proceedings and does not state additional facts or conclusions.

Ruling snapshot

  • Question: Should the Service continue following the recommendations in Chief Counsel Notice 2009-011?
  • Outcome: Advice given
  • Key authorities: IRC § 6230

Full text (IRS public release)

ID: CCA_2010011509123654 Number: 201008036
Release Date: 2/26/2010
Office: --------------
UILC: 6230.01-00

From: --------------------------
Sent: Friday, January 15, 2010 9:12:39 AM
To: ---------------------------------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
-----------------
Subject: RE: E-mailing: 4. D.C. Circuit Holds Tax Court Lacks Jurisdiction to Determine Partners' Outside
Basis * Tax Notes Today

Counsel maintains its position set forth in Chief Counsel Notice 2009-011. The Service should continue
to adhere to the recommendations in that notice.

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