Ezel / IRS Rulings / 201025075

IRS advised on extending the statute for converted items

Number
201025075
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definitions and Special Rules; Affected Item
Topics
Procedure, penalties, and administration
Code sections
§ 6231
Ruling dated
May 19, 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 the preferred form for extending the statute of limitations on converted items was the new Form 872, which specifically references converted items. It also noted that section 6231(b)(1)(D) specifically includes conversions under subsection (c).

Ruling snapshot

  • Question: Which form should be used for a statute extension involving converted items, and how does section 6231 address conversions?
  • Outcome: Advice given
  • Key authorities: IRC § 6231(b)(1)(D), (c).

Full text (IRS public release)

ID: CCA_2010051908402137 Number: 201025075
Release Date: 6/25/2010
Office: --------
UILC: 6231.00-00

From: --------------------
Sent: Wednesday, May 19, 2010 8:40:27 AM
To:
Cc:
Subject: RE: TEFRA and Bankruptcy and potential statute extension

On statute extensions for converted items, the preferred form is the new Form 872 which has language
specifically referencing converted items.

Also note that section 6231(b)(1)(D) specifically includes conversions under subsection c. --------------------
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