Ezel / IRS Rulings / 201221013

CCA 201221013: Chief Counsel says extrapolation under Revenue Procedure 2011-43 is elective

Number
201221013
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Election to Deduct or Capitalize Certain Expenditures
Topics
Income and deductions
Code sections
§ 263, § 481
Ruling dated
February 28, 2012
Publicly released
May 25, 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

Chief Counsel Advice addressed whether extrapolation was required when using the safe-harbor method in Rev. Proc. 2011-43. The advice agreed that extrapolation was not required to use the safe harbor properly. It stated that using the Appendix A extrapolation procedures to calculate a § 481(a) adjustment amount is elective.

Ruling snapshot

  • Question: Must a taxpayer use the Appendix A extrapolation procedures when calculating a § 481(a) adjustment under the safe-harbor method in Rev. Proc. 2011-43?
  • Outcome: Advice given
  • Key authorities: IRC §§ 263 and 481(a); Rev. Proc. 2011-43

Full text (IRS public release)

ID: CCA_2012022811464343 Number: 201221013
Release Date: 5/25/2012
Office: ----------------------------
UILC: 263.16-00

From: ----------------------
Sent: Tuesday, February 28, 2012 11:47:10 AM
To: ------------------------------------------
Cc: ----------------------------------------------------------------
Subject: RE: 2011-43 extrapolation

--------

It looks like you are scheduling a time to discuss this issue, which is good. I agree with your conclusion,
however, that using extrapolation is not required to properly use the safe harbor method provided in Rev.
Proc. 2011-43. Use of the extrapolation procedures provided in Appendix A for purposes of calculating a
§ 481(a) adjustment amount is elective.

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