Ezel / IRS Rulings / 201610020

Assessment ends one partnership's Form 872-A extension

Number
201610020
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Form and Contents of Waiver
Topics
Procedure, penalties, and administration
Code sections
§ 6501
Ruling dated
February 16, 2016
Publicly released
March 4, 2016
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 2016, 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 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 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 considered whether a Form 872-A consent extending the assessment period had terminated for three partnerships. An assessment attributable to one partnership ended the consent as to that partnership. The consent remained open for the other two partnerships because no assessment was attributable to either of them.

Ruling snapshot

  • Question: Did an assessment terminate a Form 872-A consent for all three partnerships?
  • Outcome: Advice given: terminated for the assessed partnership, but not for the other two.
  • Key authorities: IRC § 6501; Form 872-A

Full text (IRS public release)

~~~
ID: CCA_2016021614420347
UILC: 6501.08-17

Number: 201610020
Release Date: 3/4/2016
From:
Sent: Tuesday, February 16, 2016 2:42:03 PM
To:
Cc:
Bcc:
Subject: RE: ----- Form 872-A question

-----,

The Form 872-A has terminated with regard to partnership X because there was an
assessment attributable to partnership X. However, the Form 872-A was not terminated
with regard to partnerships Y and Z because there was no assessment attributable to
either of these partnerships.

Thank you,

~~~

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