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

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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