Ezel / IRS Rulings / 1319028
Chief Counsel Advice 1319028 Released May 10, 2013 Advice Transcribed from scan

A statute cannot be extended after it expires

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This page covers one taxpayer's ruling from 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 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.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice addresses whether a statute may be extended after it has expired. The IRS advice gives a direct answer: an expired statute cannot be extended. The memo concerns the execution of a document identified in the subject line as “9248's,” but it does not provide additional factual details.

Ruling snapshot

  • Question: Can a statute be extended after it has already expired?
  • Outcome: Advice given.
  • Key authorities: IRC § 6228.

Full text (IRS public release)

ID: CCA_2013041912304401 Number: 201319028
Release Date: 5/10/2013
UILC: 6228.02-00

From:
Sent: Friday, April 19, 2013 12:30:45 PM
To:
Cc:
Bcc:
Subject: RE: Executing 9248's

A statute cannot be extended after it has already expired.

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