Ezel / IRS Rulings / 1049040
Chief Counsel Advice 1049040 Released December 10, 2010 Advice

CCA 1049040: Form 6251 lines 3 and 8 do not apply to trade or business taxes

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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 agrees with a conclusion about Form 6251, which is used in calculating alternative minimum tax. The memorandum states that lines 3 and 8 do not apply to taxes incurred in connection with a trade or business. It cites IRC § 56 and the temporary regulation under § 62.

Ruling snapshot

  • Question: Do lines 3 and 8 of Form 6251 apply to taxes incurred in connection with a trade or business?
  • Outcome: advice given
  • Key authorities: IRC § 56(b)(1)(A) and (b)(1)(D); Treas. Reg. § 1.62-1T(d).

Full text (IRS public release)

ID: CCA-113445-10 Number: 201049040
Release Date: 12/10/2010
Office: ----------
UILC: 56.00-00

From: ---------------------
Sent: Wednesday 11/3/2010 4:45 PM
To: ------------------
Cc: ------------------
Subject: RE: Follow up Question – RE CCA

As we discussed, we agree with your conclusion. Lines 3 and 8 of Form 6251 do not apply to taxes
incurred in connection with a trade or business. See § 56(b)(1)(A), (b)(1)(D); Reg § 1.62-1T(d).

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