Ezel / IRS Rulings / 201310037

CCA 201310037: Counsel found no exception to the refund limitation rule

Number
201310037
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Limitations on Credit or Refund
Topics
Procedure, penalties, and administration
Code sections
§ 6511
Ruling dated
July 25, 2012
Publicly released
March 8, 2013
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 2013, 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 2013
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

In a brief response concerning IRC § 6511, Chief Counsel stated that the issue had been considered and that no exception to the applicable limitation rule could be found. The release does not identify additional facts or describe a different result.

Ruling snapshot

  • Question: Does an exception apply to the limitation rule under IRC § 6511?
  • Outcome: Advice given, no applicable exception was identified.
  • Key authorities: IRC § 6511

Full text (IRS public release)

ID: CCA_2012072510264026 Number: 201310037
Release Date: 3/8/2013
Office: --------------
UILC: 6511.00-00

From: -------------------
Sent: Wednesday, July 25, 2012 10:26:50 AM
To: ------------------
Cc:
Subject: RE: IRC 6511

Yes it has. I couldn't find anything that would suggest there is an exception.

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