Ezel / IRS Rulings / 201036022

CCA 201036022: IRS advice confirmed that the listed return was sufficient

Number
201036022
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Limitations on Credit or Refund (Barred v. Not Barred); Determination of Gross Income
Topics
Procedure, penalties, and administration
Code sections
§ 6501, § 6511
Ruling dated
June 30, 2010
Publicly released
September 10, 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

Chief Counsel advice concluded that the return identified by the taxpayer was sufficient, citing Internal Revenue Manual section 25.6.22.5.4. The advice appears to address whether the taxpayer's filing met a procedural requirement relevant to the limitations on credit or refund. The released text provides no additional factual or legal analysis.

Ruling snapshot

  • Question: Was the return listed by the taxpayer sufficient?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6501 and 6511; IRM 25.6.22.5.4

Full text (IRS public release)

ID: CCA_2010063012273543 Number: 201036022
Release Date: 9/10/2010
Office: --------------
UILC: 6511.00-00, 6501.07-10

From: --------------------
Sent: Wednesday, June 30, 2010 12:27:36 PM
To: ------------------
Cc:
Subject: RE: ----------872 Address

The return listed by the taxpayer is sufficient. IRM 25.6.22.5.4

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