Ezel / IRS Rulings / 201013047

CCA 201013047: IRS accepts a Form 872 extension for partnership taxes

Number
201013047
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Period of Limitations for Making Assessments
Topics
Procedure, penalties, and administration
Code sections
§ 1441, § 1442, § 1446, § 6229, § 6110
Ruling dated
March 1, 2010
Publicly released
April 2, 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 advice addressed whether a Form 872 consent extending the assessment period was acceptable for a partnership’s taxes. The memorandum stated that the form was sufficient and assumed that the partnership would sign it for the taxes it owed. The released text contains no further analysis.

Ruling snapshot

  • Question: Could a partnership use Form 872 to extend the period for assessing its taxes?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6229, 1441, 1442, and 1446; IRC § 6110(k)(3) not-precedent notice

Full text (IRS public release)

ID: CCA_2010030110462037 Number: 201013047
Release Date: 4/2/2010
Office: ----------
UILC: 6229.00-00

From: -------------------
Sent: Monday, March 01, 2010 10:46:23 AM
To: -------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------
Subject: 1441, 1442, and 1446 Withholding and TEFRA

I think the 872 is fine. I assume that it would be signed by the partnership for the taxes it owes.

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

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