Ezel / IRS Rulings / 201017050

CCA 201017050: Exceptions to COD issues operate the same way

Number
201017050
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Affected Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
April 2, 2010
Publicly released
April 30, 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 confirmed that the recipient’s second paragraph was correct regarding cancellation-of-debt issues. The message stated that the at-risk, passive-activity-loss, basis, and insolvency exceptions to cancellation of debt issues all operate the same way. It was a short clarification of how those exceptions should be treated together.

Ruling snapshot

  • Question: Do the at-risk, passive-activity-loss, basis, and insolvency exceptions operate the same way for cancellation-of-debt issues?
  • Outcome: advice given
  • Key authorities: IRC § 6231

Full text (IRS public release)

ID: CCA_2010040213372837 Number: 201017050
Release Date: 4/30/2010
Office: ----------
UILC: 6231.05-00

From: -------------------
Sent: Friday, April 02, 2010 1:37:31 PM
To: ---------------
Cc: ------------------------------------------------------
Subject: RE: Clarification Please

Your second paragraph is correct. The at risk, PALS, basis and insolvency exception to COD issues do all work the same.

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