Ezel / IRS Rulings / 1118021
Chief Counsel Advice 1118021 Released May 6, 2011 Advice

CCA 1118021: An amended return filed during an extension period supersedes the original

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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 advised that when a taxpayer is on extension and timely files an amended return within the extension period, the later return supersedes the earlier return. The later filing becomes the taxpayer's original return for the filing period. The advice was provided in response to an inquiry about which return controls.

Ruling snapshot

  • Question: Does an amended return timely filed during an extension period supersede the earlier return?
  • Outcome: Advice given.
  • Key authorities: IRC § 6012.

Full text (IRS public release)

ID: CCA_2011040809033242 Number: 201118021
Release Date: 5/6/2011
Office: --------------
UILC: 6012.00-00

From: -------------------------
Sent: Friday, April 08, 2011 9:03:38 AM
To: ----------------
Cc:
Subject: superceding return

I apologize for the delay in answering your inquiry. Obviously, litigation
matters have taken precedence over general questions given the impending
shutdown. Per my telephone message, if a taxpayer is on extension and
timely files an amendment within the extension period, that later return
supersedes the earlier return and becomes the taxpayer's original return.
Please call if you have any further questions.

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