Ezel / IRS Rulings / 201020013

CCA 201020013: Counsel addressed the treatment of carryforwards

Number
201020013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Affected Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231, § 6110
Ruling dated
April 16, 2010
Publicly released
May 21, 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

In an internal Chief Counsel email, the sender addressed how carryforwards should generally be disallowed in a TEFRA matter. The email states that carryforwards are generally disallowed through computational adjustments rather than through affected-item notices of deficiency, citing Bob Hambric Chevrolet, 849 F. Supp. 500, Cummings v. Commissioner, T.C. Memo. 1996-282, and Olson v. United States from the Second Circuit.

Ruling snapshot

  • Question: How are carryforwards generally disallowed in a TEFRA matter?
  • Outcome: Advice given
  • Key authorities: IRC § 6231; Bob Hambric Chevrolet, 849 F. Supp. 500; Cummings v. Commissioner, T.C. Memo. 1996-282; Olson v. United States (2d Cir.)

Full text (IRS public release)

ID: CCA_2010041610500937 Number: 201020013
Release Date: 5/21/2010
Office: ---------
UILC: 6231.05-00

From: --------------------
Sent: Friday, April 16, 2010 10:50:12 AM
To: ---------------------
Cc: -----------------------------
Subject: RE: question

Carryforwards are generally disallowed through computational adjustments rather than through affected
item notices of deficiency. See Bob Hambric Chevrolet, 849 F.Supp 500; Cummings v. Commissioner,
T.C. Memo. 1996-282; Olson v. U.S. (2nd Cir)

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