Ezel / IRS Rulings / 1212017
Chief Counsel Advice 1212017 Released March 23, 2012 Advice

CCA 1212017: IRS advises that an examination is not a reopening

Apply this to your situation

This page covers one taxpayer's ruling from 2012, 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 2012
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

The Office of Chief Counsel advised that examining a redacted matter as it relates to a taxpayer's one tax year would not constitute reopening another tax year. The advice concerns a question arising from Form 870-AD. It gives no further conclusion beyond that limited examination distinction.

Ruling snapshot

  • Question: Would examining a redacted matter in relation to one tax year reopen another tax year?
  • Outcome: Advice given.
  • Key authorities: IRC § 7605; 26 U.S.C. § 6110(k)(3)

Full text (IRS public release)

ID: CCA-2151710-12 Number: 201212017
Release Date: 3/23/2012
Office: --------------
UILC: 7605.01-00

From: ---------------------
Sent: Wednesday, February 15, 2012 5:03:42 PM
To: ---------------
Cc: ------------------------
Subject: RE: Question re Form 870-AD

-------, As we have discussed, examining the -------------------------------as it relates to the taxpayer’s ------
tax year does not constitute a reopening of the -------tax year. Please contact me if you have any
questions.

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2012, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.