Ezel / IRS Rulings / 201022020

CCA 201022020: Each employer remains a separate taxpayer for centralized refund communications

Number
201022020
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Authority to Make Credits or Refunds
Topics
Procedure, penalties, and administration
Code sections
§ 6402
Ruling dated
May 4, 2010
Publicly released
June 4, 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 each employer is a separate taxpayer for purposes of a refund claim. One person can centralize communications for multiple employers only if the person has a power of attorney from each taxpayer. The advice indicates that contact on the IRS side would come from Appeals.

Ruling snapshot

  • Question: Can one person centralize communications for refund claims filed by multiple employers?
  • Outcome: Advice given
  • Key authorities: IRC § 6402

Full text (IRS public release)

ID: CCA_2010050411000441 Number: 201022020
Release Date: 6/4/2010
Office: -----------------------------
UILC: 6402.00-00

From: ---------------
Sent: Tuesday, May 04, 2010 11:00:07 AM
To: ------------------------------------------------------------------------------------------------------------------
Cc: ----------------------
Subject: refund claim protests

Each separate employer is a separate taxpayer and for one person to be able to centralize
communications, presumably POAs would be needed by each taxpayer.

As for contact on IRS side, yes, I would think that would come from Appeals.

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