Ezel / IRS Rulings / 201416008
Chief Counsel Advice 201416008 Released April 18, 2014 Advice

Refund period after partnership administrative adjustment requests

Apply this to your situation

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

Chief Counsel advice addresses how long the IRS may issue refunds after a tax matters partner files an administrative adjustment request. It says the refund period generally expires two years after the partnership-level request, unless an applicable extension applies. A partner-level administrative adjustment request starts a separate two-year refund period for that partner. The advice also explains that a Form 872-P agreement before the normal section 6229(a) period can extend the refund period to the agreed date plus six months.

Ruling snapshot

  • Question: How do partnership-level and partner-level administrative adjustment requests affect the period for issuing refunds?
  • Outcome: Advice given
  • Key authorities: IRC §§ 6227(b)(2) and 6229(a)

Full text (IRS public release)

ID: CCA_2014021115284101 [Third Party Communication:

UILC: 6227.05-00, 6227.05-00 Date of Communication: Month DD, YYYY]

Number: 201416008
Release Date: 4/18/2014
From:
Sent: Tuesday, February 11, 2014 3:28:41 PM
To:
Cc:
Bcc:
Subject: RE: AAR Question - Refund Statute

One clarification. The extension in the second sentence below would extend the period for partner-
level AAR’s which would, if filed during that period, extend the period for issuing a refund based on that
partner-level AAR for 2 years from the date of the partner AAR.

The reference in the first sentence to Form 9247 was meant to be to Form 9248.

From:
Sent: Tuesday, February 11, 2014 2:33:33 PM
To:
Cc:
Subject: RE: AAR Question - Refund Statute

The period for issuing refunds will expire 2 years after the TMP AAR or longer if he signs a Form 9247. It
does not appear that an extension on Form 9248 to ------------would do anything other than extend the 2
year period by one day.

If the TMP signed a Form 872-P before the normal section 6229(a) period, this would extend the refund
period to the agreed date plus 6 months. I.R.C. 6227(b)(2).

Any partner level AAR would extend the refund statute for that partner for 2 years from the date of the
partner-level AAR.

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2014, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.