Receiver appointment starts a one-year TEFRA limitations period

Plain-English summary

Chief Counsel advised that the one-year period under IRC § 6229(f), during which a partner's IRC § 6501 limitations period will not expire, began when a receiver was appointed. Because that one-year period had expired, the IRS would have to rely on the taxpayer's underlying § 6501 period for the affected years. Taxable years ending before the receiver's appointment had converted and were subject to deficiency procedures.

Ruling snapshot

• Question: When does the one-year limitations period under IRC § 6229(f) begin after a receiver is appointed?
• Outcome: Advice given.
• Key authorities: IRC §§ 6229(f) and 6501.

Full text (IRS public release)

ID: CCA-913844-10 Number: 201108030
Release Date: 2/25/2011
Office: ----------
UILC: 6229.00-00

From: -------------------
Sent: Mon 9/13/2010 8:44 AM
To: ------------------
Cc: ---------------------------------------------------------------------------------------------------------------------------
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Subject: RE: Convert TEFRA Investor

You are correct that the one year date under section 6229(f) during which the partner's section 6501 statute will not expire started on that date a receiver was appointed. Since that year has already expired you will have to rely on the taxpayer's underlying section 6501 period for all affected years. All taxable years ending before that date the receiver was appointed have now converted and are, thus, now subject to deficiency procedures.