Ezel / IRS Rulings / 1221014
Chief Counsel Advice 1221014 Released May 25, 2012 Advice

CCA 1221014: Chief Counsel addresses the assessment period for restitution

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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

Chief Counsel Advice addressed the period for assessing restitution. It stated that IRC § 6501(c)(11) allows an assessment of the restitution amount described in § 6201(a)(4) at any time. The advice noted that this language is nearly identical to the unlimited assessment provision for fraud in § 6501(c)(1).

Ruling snapshot

  • Question: Is an assessment of the restitution amount described in IRC § 6201(a)(4) subject to a time limit?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6501(c)(1), 6501(c)(11), and 6201(a)(4)

Full text (IRS public release)

                                               1

ID: CCA-321145-12 Number: 201221014
Release Date: 5/25/2012
Office: -------------
UILC: 6501.00-00, 6201.00-00

From: ------------------------
Sent: Wednesday, March 21, 2012 2:55 PM
To: ----------------------
Cc: -------
Subject: Restitution Question!

Section 6501(c)(11) provides that an assessment of the amount of restitution provided in section
6201(a)(4) may be assessed at any time. The language is almost identical to the unlimited fraud
assessment provision of section 6501(c)(1).

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