Ezel / IRS Rulings / 201610019
Chief Counsel Advice 201610019 Released March 4, 2016 Advice

Form 872 may extend the section 6501(f) assessment period

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This page covers one taxpayer's ruling from 2016, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2016
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 advised that Form 872 may extend an assessment period that remains open under section 6501(f), even if the ordinary three-year period under section 6501(a) has expired. No additional language needs to be added to the form. The form's tax-type field should identify income tax because personal holding company tax is a type of income tax.

Ruling snapshot

  • Question: Could Form 872 extend a section 6501(f) assessment period after the normal three-year period expired?
  • Outcome: Advice given: yes, without adding special language to the form.
  • Key authorities: IRC §§ 6501(a) and 6501(f); Form 872

Full text (IRS public release)

~~~
ID: CCA-02240854-16
UILC: 6501.08-00

Number: 201610019
Release Date: 3/4/2016
From:
Sent: Wednesday, February 24, 2016 8:54 AM
To:
Cc:
Bcc:
Subject: IRC section 6501(f)

-------,

A Form 872 can be used to extend a period of limitation on assessment that is still open
under section 6501(f), even if the normal three year period of limitation under section
6501(a) would otherwise have expired. There is no need to amend the form with
additional language. The “kind of tax field” on the form should be filled out with income
tax because the personal holding company tax is a type of income tax.

Please feel free to contact me with any questions or concerns.

Respectfully Yours,

~~~

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