Ezel / IRS Rulings / 1116027
Chief Counsel Advice 1116027 Released April 22, 2011 Advice

CCA 1116027: IRS advised that a taxpayer generally may not undo a credit elect

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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 whether a taxpayer could undo a credit elect. The short answer was no. The IRS stated that a taxpayer may not generally undo a credit elect.

Ruling snapshot

  • Question: May a taxpayer generally undo a credit elect?
  • Outcome: Advice given
  • Key authorities: IRC § 6402

Full text (IRS public release)

ID: CCA_2011032813332942 Number: 201116027
Release Date: 4/22/2011
Office: --------------
UILC: 6402.00-00

From: -------------------------
Sent: Monday, March 28, 2011 1:33:30 PM
To: ----------------------------------------
Cc:
Subject: credit elects

Short answer, no. A taxpayer may not generally undo a credit elect.

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