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Ezel / IRS Rulings / 201610020
Chief Counsel Advice 201610020 Released March 4, 2016 Advice

Assessment ends one partnership's Form 872-A extension

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This page covers one taxpayer's ruling from 2016, 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 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 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 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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