Ezel / IRS Rulings / 201016067

CCA 201016067: An AAR is timely when filed within the period set by the Forms 872-i

Number
201016067
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Administrative Adjustments Requests
Topics
Procedure, penalties, and administration
Code sections
§ 6227, § 6229
Ruling dated
March 19, 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 an administrative adjustment request is timely if it is filed within the time limit established by the Forms 872-i. Section 6227(b) extends the period for filing an AAR when there is an agreement under section 6229(b). The advice concludes that Form 872-i meets the relevant criterion because it specifically refers to tax attributable to partnership items.

Ruling snapshot

  • Question: When is an administrative adjustment request timely under the period extended by Forms 872-i?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6227(b) and 6229(b)

Full text (IRS public release)

ID: CCA_2010031908381937 Number: 201016067
Release Date: 4/23/2010
Office: ----------
UILC: 6227.00-00

From: -------------------
Sent: Friday, March 19, 2010 8:38:26 AM
To: -------------------------
Cc: -----------
Subject: RE: SOL of AAR

The AAR is timely if filed within the time limit set forth by the Forms 872-i. Section 6227(b) extends the
period for fling an AAR by any agreement under section 6229(b).
The Form 872i meets this criteria since it specifically includes language referencing tax attributable to part
nership items.

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