Ezel / IRS Rulings / 201319028

A statute cannot be extended after it expires

Number
201319028
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Period for Filing Petition
Topics
Procedure, penalties, and administration
Code sections
§ 6228
Ruling dated
April 19, 2013
Publicly released
May 10, 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.
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.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace