Ezel / IRS Rulings / 201016064

CCA 201016064: Section 6230(d) bars a refund after the applicable statutes expire

Number
201016064
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Time for Filing Claim
Topics
Procedure, penalties, and administration
Code sections
§ 6230
Ruling dated
March 17, 2010
Publicly released
April 23, 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 states that section 6230(d) prevents the Service from issuing a refund after the statutes referenced in that subsection have expired. The advice gives no further facts or analysis in the released text.

Ruling snapshot

  • Question: May the Service issue a refund after the statutes referenced in section 6230(d) have expired?
  • Outcome: Advice given
  • Key authorities: IRC § 6230(d)

Full text (IRS public release)

ID: CCA_2010031711024837 Number: 201016064
Release Date: 4/23/2010
Office: ----------
UILC: 6230.03-01

From: -------------------
Sent: Wednesday, March 17, 2010 11:02:51 AM
To: -------------------
Cc: -----------
Subject: RE: AAR Case Documentation

Section 6230(d) is pretty clear that we cannot issue a refund after the statutes referenced in that section
have expired. ------------------------------------------------------------------------------------------------------------------------
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