Ezel / IRS Rulings / 201116026

CCA 201116026: Form 872-i extends the period for a partner to file an AAR

Number
201116026
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Other Requests
Topics
Procedure, penalties, and administration
Code sections
§ 6227
Ruling dated
March 25, 2011
Publicly released
April 22, 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 effect of a Form 872-i, or a Form 872 with added language referring to partnership items. The IRS advised that this form extends the period for a partner to file an administrative adjustment request under IRC § 6227(b). The release is a short email-style memorandum with no further factual analysis.

Ruling snapshot

  • Question: Does a Form 872-i extend the period for a partner to file an AAR under IRC § 6227(b)?
  • Outcome: Advice given
  • Key authorities: IRC § 6227(b)

Full text (IRS public release)

ID: CCA_2011032515390337 Number: 201116026
Release Date: 4/22/2011
Office: CC:PA
UILC: 6227.05-00

From: -------------------
Sent: Friday, March 25, 2011 3:39:08 PM
To: ---------------
Cc: -----------
Subject: RE: 872-P for ------

A Form 872-i, of a Form 872 with added language referencing partnership items, extends the period for a
partner to file an AAR under section 6227(b).

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace