Ezel / IRS Rulings / 201025061

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

Number
201025061
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Notice to Partners of Proceedings
Topics
Procedure, penalties, and administration
Code sections
§ 6223
Ruling dated
May 27, 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 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.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace