Ezel / IRS Rulings / 201221016

CCA 201221016: Chief Counsel addresses TEFRA extensions of the assessment period

Number
201221016
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Suspension of Statutory Period
Topics
Procedure, penalties, and administration
Code sections
§ 6229, § 6501
Ruling dated
April 30, 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 how IRC §§ 6229 and 6501 interact in a TEFRA case. The advice said § 6229 extends a partner's § 6501 assessment period, citing decisions from three circuit courts and an en banc Tax Court opinion. It concluded that § 6501(c)(7) can operate on a partner's § 6501 assessment period when that period has been extended under § 6229(d)(2). The advice referred to Chief Counsel Notice CC-2009-027.

Ruling snapshot

  • Question: Can IRC § 6501(c)(7) operate on a partner's assessment period after the period has been extended under § 6229(d)(2)?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6229, 6229(d)(2), and 6501(c)(7); Chief Counsel Notice CC-2009-027

Full text (IRS public release)

ID: CCA_2012043014110937 Number: 201221016
Release Date: 5/25/2012
Office: ---------
UILC: 6229.04-00

From: --------------------
Sent: Monday, April 30, 2012 2:11:20 PM
To: --------------------
Cc: ------------------------------------
Subject: RE: Question regarding TEFRA statute dates

Section 6229 operates to extend a partner's section 6501 period for assessment as held by three Circuit
Court's of appeal and an en banc opinion of the Tax Court. See the Notice on Frequently asked TEFRA
questions attached. Consequently, section 6501(c)(7) can operate on a partner's section 6501 period for
assessment that has been extended by section 6229(d)(2).

Attachment: Chief Counsel Notice CC-2009-027

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