Ezel / IRS Rulings / 201447032

One Form 872 is sufficient for the taxpayer's limitations extension

Number
201447032
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Limitations on Assessment and Collection (Barred v. Not Barred)
Topics
Procedure, penalties, and administration
Code sections
§ 6501
Ruling dated
November 6, 2014
Publicly released
November 21, 2014
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 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 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.
View official IRS release (PDF)

Plain-English summary

Chief Counsel addressed how to extend one taxpayer's assessment limitations period on the facts supplied by the requester. The advice stated that the taxpayer needed to complete only one Form 872. That form could contain the taxpayer's information alone. The short email did not describe the underlying tax matter or identify any additional parties whose consent might otherwise have been considered.

Ruling snapshot

  • Question: What consent form was needed to extend the taxpayer's assessment limitations period?
  • Outcome: Advice given that one Form 872 containing only the taxpayer's information was sufficient
  • Key authorities: Form 872; IRC § 6501 limitations procedures

Full text (IRS public release)

ID: CCA_2014110612045710 Third Party Communication: None

UILC: 6501.00-00 Date of Communication: Not Applicable

Number: 201447032
Release Date: 11/21/2014
From:
Sent: Thursday, November 06, 2014 12:04:57 PM
To:
Cc:
Bcc:
Subject: FW: Statute Extension Question

Sorry I missed your return call. Based on the facts provided, in order to extend his statute it is sufficient
that TPH complete a single Form 872 with his information only. If you have any questions please let me
know.

Best,
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