Ezel / IRS Rulings / 201212017

CCA 201212017: IRS advises that an examination is not a reopening

Number
201212017
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Restrictions on Examination of Taxpayer
Topics
Procedure, penalties, and administration
Code sections
§ 7605, § 6110
Ruling dated
February 15, 2012
Publicly released
March 23, 2012
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 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 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

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.

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