Ezel / IRS Rulings / 1025061
Chief Counsel Advice 1025061 Released June 25, 2010 Advice

IRS advised that a closing conference is not legally required before an FPAA

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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 there is no legal requirement to grant a closing conference. It stated that the IRS could proceed directly to issuing an FPAA when the applicable statute of limitations was about to expire.

Ruling snapshot

  • Question: Must the IRS grant a closing conference before issuing an FPAA?
  • Outcome: Advice given
  • Key authorities: IRC § 6223.

Full text (IRS public release)

ID: CCA_2010052708315937 Number: 201025061
Release Date: 6/25/2010
Office: ----------
UILC: 6223.00-00

From: --------------------
Sent: Thursday, May 27, 2010 8:32:06 AM
To: --------------
Cc: ------------
Subject: RE: Closing Conference/Summary Report

There is no legal requirement to grant a closing conference. So we can go directly to issuing an FPAA if
the statute is about to expire.

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