Ezel / IRS Rulings / 1328032
Chief Counsel Advice 1328032 Released July 12, 2013 Advice

CCA 1328032: Who may sign Form 907 for an extension of time to sue

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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.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advice identifies the authority for signing Form 907 to extend the time for filing suit in an Appeals matter. It points to IRM § 8.7.7.2.4(5), which authorizes Appeals Area Directors to execute the form under Delegation Order 8-4. The advice also states that Form 907 instructions identify the appropriate IRS signatory by operating unit when other units are involved.

Ruling snapshot

  • Question: Who may sign Form 907 on behalf of the IRS?
  • Outcome: Advice given.
  • Key authorities: IRC § 6532; IRM §§ 1.2.47.5, 8.7.7.2.4(5); Delegation Order 8-4.

Full text (IRS public release)

ID: CCA-5141058-13
Office: --------------
UILC: 6532.02-04
Number: 201328032
Release Date: 7/12/2013
From: ---------------------
Sent: Tuesday, May 14, 2013 10:58 AM
To: ---------------------
Cc: ------------------
Subject: Who can sign Form 907

I received the question you had about who can sign Form 907 from ------------------------.

There is one delegation order that specifically covers this question in the context of
Appeals. IRM 8.7.7.2.4(5) says: “Appeals Area Directors are authorized to execute Form
907 to extend the time for filing suit. See Delegation Order 8-4 (formerly DO 171, Rev. 2)
at IRM 1.2.47.5.”

There do not appear to be any other delegation orders that specifically address this Form.
However, the instructions to Form 907 contain a section for IRS Employees that lists who
should sign the Form on behalf of the IRS, depending on the unit involved (SB/SE, WI,
LMSB, etc.). These instructions should be sufficient to determine who should sign the
form.

Please let me know if you have any other questions or would like to discuss further.
Thanks.

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