Ezel / IRS Rulings / 201048038

CCA 201048038: The taxpayer had properly adopted its tax year

Number
201048038
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definition of Taxable Year
Topics
Accounting methods and periods
Code sections
§ 441
Ruling dated
September 23, 2010
Publicly released
December 3, 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 reviewed a request to change a taxpayer's tax year. The submitted return indicated that the taxpayer had already properly adopted the requested tax year when it filed its first return for the relevant period. The IRS advised correcting the records if they did not reflect that adoption under Treasury Regulation § 1.441-1(c).

Ruling snapshot

  • Question: Had the taxpayer already properly adopted the requested tax year?
  • Outcome: advice given
  • Key authorities: Treas. Reg. § 1.441-1(c).

Full text (IRS public release)

ID: CCA-923843-10 Number: 201048038
Release Date: 12/3/2010
Office: ----------------
UILC: 441.01-00

From: ------------------------
Sent: Thu 9/23/2010 8:43 AM
To: ----------------------
Cc:
Subject: Form 1128 --------

-------- --------- forwarded a Form ------- to the national office for ----------------------------------
------------------------------. The form indicates that the taxpayer is requesting to change to a --------tax year, effective ---------------. However, copy of tax return submitted indicates that the taxpayer properly adopted a -------- tax year when it filed its first return for the period ------------------------- though --------------------------. If your records do not reflect a --
-------- tax year please correct them. Taxpayer properly adopted its tax year under section 1.441-1(c).

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