Limitations period for income tax and information-return penalties

Plain-English summary

The Chief Counsel advice addresses whether the assessment period remained open for income tax and penalties related to Forms 3520-A and 5471. It concludes that the limitations period remained open through the redacted date under section 6501(c)(8). It also states that timely executed Forms 872 further extended the limitations period for both the income tax and penalties.

Ruling snapshot

• Question: Did section 6501(c)(8), together with Forms 872, keep the assessment period open for the identified tax years and penalties?
• Outcome: Advice given
• Key authorities: IRC § 6501(c)(8)

Full text (IRS public release)

ID: CCA_2013120910424107 [Third Party Communication:

UILC: 6501.04-03
Date of Communication: Month DD, YYYY]

Number: 201402013
Release Date: 1/10/2014
From:
Sent: Monday, December 09, 2013 10:42:42 AM
To:
Cc:
Bcc:
Subject: RE: Request for case assignment - OVDP case -- ----------------------

-------concurs with you that the statutes of limitation on assessment of the income tax for tax years ---------------, and the resulting penalties for failing to file the Forms 3520-A and 5471 for those years remains open until -----------------as a result of the application of section 6501(c)(8) and as further extended by the timely executed Forms 872 extending the period of limitations on both the income tax and penalties until ----------------.