Ezel / IRS Rulings / 201049040

CCA 201049040: Form 6251 lines 3 and 8 do not apply to trade or business taxes

Number
201049040
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Adjustments In Computing Alternative Minimum Taxable Income
Topics
Income and deductions
Code sections
§ 56, § 62
Ruling dated
November 3, 2010
Publicly released
December 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 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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