Ezel / IRS Rulings / 201008041

CCA 201008041: No legal limit on sequential filings to keep the refund statute open

Number
201008041
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Period for Filing Petition
Topics
Procedure, penalties, and administration
Code sections
§ 6228
Ruling dated
January 25, 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 there is no legal limit on securing Forms 9248 in sequence to keep the refund statute open. The short advice concerns the period for filing a petition under section 6228. The CCA does not state additional facts or identify a separate limitation on the sequential filings.

Ruling snapshot

  • Question: Is there a legal limit on securing Forms 9248 in sequence to keep the refund statute open?
  • Outcome: Advice given
  • Key authorities: IRC § 6228

Full text (IRS public release)

ID: CCA_2010012510104437 Number: 201008041
Release Date: 2/26/2010
Office: ----------
UILC: 6228.02-00

From: -------------------
Sent: Monday, January 25, 2010 10:10:47 AM
To: -------------------------------------------
Cc: ---------------------------------------------------
Subject: RE: 4-4 Report

There is no legal limit on securing Forms 9248 in sequence to keep the refund statute open. -----------------
--------------------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------

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