Chief Counsel Advice 201933012 Released August 16, 2019 Advice

Each taxpayer must sign Form 921-I to extend the assessment period

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This page covers one taxpayer's ruling from 2019, 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 2019
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 taxpayers should execute Form 921-I when a flow-through entity extends the assessment period for each owner’s share of common-improvement costs. The basic Form 921 applies to individual taxpayers and is not used in this flow-through situation. Each affected partner, shareholder, or beneficiary must instead sign a Form 921-I. One Form 921-I does not suffice for all affected taxpayers.

Ruling snapshot

  • Question: Must affected taxpayers sign both Form 921 and Form 921-I, or only Form 921-I?
  • Outcome: advice given that each affected taxpayer must sign Form 921-I, without also signing the basic Form 921
  • Key authorities: IRC § 6501; Rev. Proc. 92-29

Full text (IRS public release)

ID:         CCA_2019072215220148
UILC:       6501.08-03, 6501.00-00

Number: 201933012
Release Date: 8/16/2019
From:
Sent: Monday, July 22, 2019 3:22:01 PM
To:
Cc:
Bcc:
Subject: RE: Rev. Proc. 92-29 Statute Extension Advice


Hi ------

You asked us whether the instructions on Form 921-I requiring that “Form 921 must be
signed by each partner/shareholder/beneficiary” requires that applicable taxpayers sign
both a Form 921-I and the basic Form 921, or whether Form 921-I is sufficient. The
answer is that Form 921-I only must be signed by each applicable taxpayer.

The basic Form 921 is a consent for individual taxpayers and is wholly inapplicable to
the Form 921-I situation, in which a flow-through entity extends its
partner/shareholder/beneficiaries’ assessment statute for the allocable share of
common improvements. The instructions on Form 921-I should therefore be understood
to require only that the applicable Form 921—specifically, Form 921-I—be signed by
each partner/shareholder/beneficiary. While Form 921-I rather than the basic Form 921
is the correct form with the instructions properly understood, the instruction is still
important as it clarifies that a single Form 921-I will not suffice: a Form 921-I must be
signed by each partner/shareholder/beneficiary.




Let me know if you have any further questions or concerns.

Thanks.


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