Ezel / IRS Rulings / 201109021

CCA 201109021: Section 6229 keeps the section 6501 period open for affected items

Number
201109021
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Roth IRA Excise Tax
Topics
Procedure, penalties, and administration
Code sections
§ 6229, § 6231, § 6501
Ruling dated
February 7, 2011
Publicly released
March 4, 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 period for assessing a related excise tax treated as an affected item of a partnership. It concluded that IRC § 6229 keeps the IRC § 6501 period open for every partner with respect to affected items. The advice stated that affected items include items outside subtitle A, including penalties under subtitle F.

Ruling snapshot

  • Question: Does section 6229 keep the section 6501 period open for partnership affected items such as related excise taxes?
  • Outcome: Advice given.
  • Key authorities: IRC §§ 6229, 6231, and 6501.

Full text (IRS public release)

ID: CCA_2011020713572237 Number: 201109021
Release Date: 3/4/2011
Office: ----------
UILC: 6231.05-00

From: -------------------
Sent: Monday, February 07, 2011 1:57:30 PM
To: ----------------------
Cc: -------------------------------------
Subject: RE: Roth IRA Excise Tax

Section 6229 provides that the period under section 6501 shall not expire for any partnership item or affected item. So section 6229 keeps the section 6501 statute open for every partner for affected items such as related excise taxes. Affected items include items outside subtitle A including penalties under subtitle F.

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