Ezel / IRS Rulings / 201115021

Two-year period runs from the FPAA petition deadline

Number
201115021
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Time for Filing Claim
Topics
Procedure, penalties, and administration
Code sections
§ 6230
Ruling dated
March 10, 2011
Publicly released
April 15, 2011
Source
View Official PDF

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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 timing of a claim under IRC § 6230(c)(2)(b)(ii) after a no-change closure involving an FPAA. It states that the two-year period runs from the expiration of the 150-day period for filing a petition challenging the FPAA.

Ruling snapshot

  • Question: When does the two-year period under IRC § 6230(c)(2)(b)(ii) begin?
  • Outcome: Advice given
  • Key authorities: IRC § 6230(c)(2)(b)(ii)

Full text (IRS public release)

ID: CCA_2011031009520037 Number: 201115021
Release Date: 4/15/2011
Office: ----------
UILC: 6230.03-01

From: -------------------
Sent: Thursday, March 10, 2011 9:52:06 AM
To: -----------------------------------------
Cc:
Subject: RE: No Change closure with L2621 and 6230(c) ---------

The two year period under section 6230(c)(2)(b)(ii) would run from the expiration of the petition period
(150 days) for the FPAA.

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