Ezel / IRS Rulings / 201112009

CCA 201112009: Form 2848 was invalid after an officer left the organization

Number
201112009
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Miscellaneous Issues
Topics
Other topics
Code sections
§ 6110
Publicly released
March 25, 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 agreed that Form 2848 was invalid because the person identified on it was no longer a bona fide officer of the organization. The release does not identify a Code section supporting the advice.

Ruling snapshot

  • Question: Is Form 2848 valid when the named representative is no longer a bona fide officer of the organization?
  • Outcome: Advice given.
  • Key authorities: IRC § 6110(k)(3) governs the nonprecedential status; no substantive Code section is stated in the release.

Full text (IRS public release)

ID: CCA-10151255-10 Number: 201112009
Release Date: 3/25/2011
Office: ----------
UILC: 9999.00-00

From: ---------------------
Sent: Friday, October 15, 2010 12:55 PM
To: -------------------------
Cc: ----------------------------------------------------------------
Subject: RE: Received 2848

I concur that the Form 2848 is invalid since ----------- is no longer a bona fide officer of --
------

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