Training lesson revises collection limitation suspension guidance

Plain-English summary

Chief Counsel reported that a levy, seizure, and sale training lesson had been revised to correct legal inaccuracies in its discussion of IRC § 6503 suspensions. The revision expanded the explanation of how suspension works in jeopardy situations. It also added a practice tip to refer the matter to “DJ” when the nominal collection statute expiration date begins to run, even though the IRS position is that the deadline is extended. The short message provides no further facts or legal analysis.

Ruling snapshot

• Question: What revisions were made to the training lesson's discussion of limitation-period suspensions?
• Outcome: Advice given. The lesson corrects inaccuracies, expands jeopardy guidance, and adds a referral practice tip.
• Key authorities: IRC § 6503

Full text (IRS public release)

ID: CCA_2017031413035557
UILC: 6503.00-00

Number: 201721016
Release Date: 5/26/2017
From:
Sent: Tuesday, March 14, 2017 1:03:55 PM
To:
Cc:
Bcc:
Subject: Lesson 8 (Levy Seizure Sale)

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FYI, the discussion on section 6503 suspensions has been revised in the above-
referenced lesson (the current one in the 2017 GL1 drive). Legal inaccuracies have
been cleaned up and there is a beefed up discussion of how the suspension operates in
jeopardy situations. It also has a practice tip (refer to DJ as the nominal CSED begins
to run, even though our position is that there is a CSED extension).

Let me know if have any questions.

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