Ezel / IRS Rulings / 1025058
Chief Counsel Advice 1025058 Released June 25, 2010 Advice

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

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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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