Ezel / IRS Rulings / 201027047

CCA 201027047: Certified-mail notice started the two-year period for suit

Number
201027047
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Periods of Limitation on Suits (Barred v. Not Barred)
Topics
Procedure, penalties, and administration
Code sections
§ 6532
Ruling dated
June 4, 2010
Publicly released
July 9, 2010
Source
View Official PDF

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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

Chief Counsel Advice concludes that a notice sent by certified mail and partially disallowing a claim was valid. The notice started the two-year limitation period under section 6532(a)(1). The Service could sign Form 907.

Ruling snapshot

  • Question: Did the certified-mail notice start the limitation period for a suit on the claim?
  • Outcome: advice given
  • Key authorities: IRC § 6532(a)(1); Form 907

Full text (IRS public release)

ID: CCA_2010060409101936 Number: 201027047
Release Date: 7/9/2010
Office: ----- ---------
UILC: 6532.00-00

From: --------------------
Sent: Friday, June 04, 2010 9:10:24 AM
To: ------------------
Cc: -----------------------
Subject: Your question

Because the notice was issued by certified mail and disallowed the claim (in part), it
was valid and the two-year limitation period under section 6532(a)(1) started at that
time. The Service may sign the Form 907.

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