Ezel / IRS Rulings / 1033033
Chief Counsel Advice 1033033 Released August 20, 2010 Advice

CCA 1033033: Section 530 issues may have been irrelevant after the taxpayer closed

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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

Chief Counsel Advice considered issues involving the section 530 employment-tax safe harbor in a particular case. The writer believed the issues related to the case’s section 530 hazards and that the taxpayer was assumed to qualify under section 530 going forward. The writer also recalled that the taxpayer was out of business, which would make that assumption irrelevant, and noted that the prior audit safe harbor would not extend to another taxpayer. The memorandum is tentative and uses redacted references.

Ruling snapshot

  • Question: How did section 530 safe-harbor considerations affect the employment-tax case?
  • Outcome: advice given
  • Key authorities: IRC § 3121; Revenue Act of 1978 § 530

Full text (IRS public release)

ID: CCA_2010070612323941 Number: 201033033
Release Date: 8/20/2010
Office: -----------------------------
UILC: 3121.10-00

From: ---------------
Sent: Tuesday, July 06, 2010 12:32:41 PM
To: --------------------------------------------------------------
Cc:
Subject: RE: ET case

I think all of those things relate to our 530 hazards in this case. I think we assumed the
TP would have 530 going forward, except I seem to recall this TP is out of business so
irrelevant and the prior audit safe harbor would not reach any other TP.

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