Ezel / IRS Rulings / 201402013
Chief Counsel Advice 201402013 Released January 10, 2014 Advice

Limitations period for income tax and information-return penalties

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This page covers one taxpayer's ruling from 2014, 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 2014
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

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 ----------------.

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