Ezel / IRS Rulings / 201101022

CCA 201101022: Chief Counsel identifies the notice referenced by section 6227(d)(4)

Number
201101022
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Other Requests
Topics
Procedure, penalties, and administration
Code sections
§ 6227
Ruling dated
November 18, 2010
Publicly released
January 7, 2011
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 2011, 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 2011
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 addressed the cross-reference in IRC § 6227(d)(4). It states that the provision refers to the issuance of a notice of the beginning of an administrative proceeding under IRC § 6223(a)(1). The advice identifies which notice triggers the referenced rule.

Ruling snapshot

  • Question: What notice does IRC § 6227(d)(4) refer to?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6227(d)(4) and 6223(a)(1)

Full text (IRS public release)

ID: CCA_2010111813302737 Number: 201101022
Release Date: 1/7/2011
Office: ----------
UILC: 6227.05-00

From: --------------------
Sent: Thursday, November 18, 2010 1:30:32 PM
To: ------------------
Cc: ------------
Subject: RE: Amended Form 1040X

Section 6227(d)(4) refers to the issuance of a notice of beginning of administrative proceeding under
section 6223(a)(1).

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