Ezel / IRS Rulings / 201025058

IRS addressed the timeliness of a refund claim without reaching its merits

Number
201025058
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Payment Date
Topics
Procedure, penalties, and administration
Code sections
§ 6511
Ruling dated
May 25, 2010
Publicly released
June 25, 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

The IRS advised that, for limitations purposes, the taxpayer was entitled to make a refund claim for the redacted amount. It expressly stated that the advice did not address whether the claim had merit.

Ruling snapshot

  • Question: What amount may the taxpayer claim for limitations purposes?
  • Outcome: Advice given
  • Key authorities: IRC § 6511.

Full text (IRS public release)

ID: CCA_2010052510355543 Number: 201025058
Release Date: 6/25/2010
Office: ----------------------------
UILC: 6511.02-00

From: --------------------
Sent: Tuesday, May 25, 2010 10:36:05 AM
To: ----------------------------------
Cc:
Subject: RE: Refund Interest Claim ---------

For limitations purposes, the taxpayer is entitled to make the claim in the amount of $-------, but I am not
opining on the merits of the claim.

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