Ezel / IRS Rulings / 201018013

CCA 201018013: Chief Counsel advised on renewing statute extensions

Number
201018013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Extension by Agreement
Topics
Procedure, penalties, and administration
Code sections
§ 6229, § 6241, § 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 which forms to use when renewing and extending existing statute extensions for tax years 2002 through 2006. The advice recommended using the identical forms and language for those renewals and using the new form, with appropriate limitations, for later years. It also noted that TEFRA had been repealed for S corporations in 1996, making the described TEFRA S corporation doubtful.

Ruling snapshot

  • Question: Which forms should be used for renewing and extending existing statute extensions?
  • Outcome: Advice given
  • Key authorities: IRC § 6229; former IRC § 6241 et seq.

Full text (IRS public release)

ID: CCA_2010041408381737 Number: 201018013
Release Date: 5/7/2010
Office: ----------
UILC: 6229.02-00

From: -------------------
Sent: Wednesday, April 14, 2010 8:38:23 AM
To: --------------------
Cc: -----------
Subject: RE: New Form 872

I would use the identical forms and language if you are just renewing and further extending the existing
statute extensions, 2002 through 2006.

I would start using the new form with any appropriate limitations for years after 2006.

TEFRA was repealed for S corporations in 1996 so I doubt that you have a TEFRA S corporation as
stated. See former I.R.C. 6241 et seq repealed by Small Business Job Protection Act of 1996.

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