Chief Counsel Advice 201748009 Released December 1, 2017 Advice

Combat-zone disregarded days use the taxpayer's entry date

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This page covers one taxpayer's ruling from 2017, 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 2017
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 how to compute the section 7508 period that is disregarded for tax deadlines when a taxpayer serves in a combat zone. The relevant date for measuring the filing-season days remaining is the date the taxpayer entered the combat zone. Those remaining filing-season days are included in the disregarded period because the cited revenue ruling measures them when combat-zone service began. The email gave no further factual or computational detail.

Ruling snapshot

  • Question: Which date determines the remaining filing-season days included in the section 7508 disregarded period?
  • Outcome: advice given, use the combat-zone entry date
  • Key authorities: IRC § 7508; the revenue ruling quoted in the advice

Full text (IRS public release)

ID:       CCA_2017102313372053
UILC:     7508.00-00

Number: 201748009
Release Date: 12/1/2017
From:
Sent: Monday, October 23, 2017 1:37:20 PM
To:
Cc:
Bcc:
Subject: RE: Technical Application of IRC 7508 with respect to the computation of interest and other
additions to tax based on the return due date


Hello ---------

----------- is correct. The date that matters for determining how many remaining filing
season days are included in the disregarded count is the entry date. The Rev. Rul.
states that the disregarded days include the filing season days remaining “at the time
the taxpayer began serving in the combat zone.”

If you still have a concern about this, please discuss it with your manager.

Thanks.
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