Ezel / IRS Rulings / 201018012

CCA 201018012: Chief Counsel addressed a deposit applied to another tax year

Number
201018012
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Deposits
Topics
Procedure, penalties, and administration
Code sections
§ 6603, § 6110
Ruling dated
April 14, 2010
Publicly released
May 7, 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 the consequences of applying a tax deposit as a payment to another year. The advice stated that the taxpayer could make an administrative claim for refund for that year if the taxpayer contested the liability for it. The memorandum is limited to this short question and answer.

Ruling snapshot

  • Question: Can a taxpayer seek a refund after a deposit is applied as a payment to another year?
  • Outcome: Advice given
  • Key authorities: IRC § 6603.

Full text (IRS public release)

ID: CCA_2010041407365141 Number: 201018012
Release Date: 5/7/2010
Office: ----------
UILC: 6603.00-00

From: -------------------
Sent: Wednesday, April 14, 2010 7:36:59 AM
To: -----------------------
Cc:
Subject: RE: Rev. Proc. 2005-18

No, but once the deposit is applied as a payment to another year, the TP can make an administrative
claim for refund with respect to that year, assuming the TP contests the liability for that year.

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