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Chief Counsel Advice 201740021 Released October 6, 2017 Advice

Disaster postponement suspends assessment deadline

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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 that section 7508A suspends the time for the IRS to make assessments during the postponement period that applies to a declared disaster. The short email pointed to examples in the regulations and copied another official with greater disaster-relief expertise.

Ruling snapshot

  • Question: Does a disaster postponement also suspend the deadline for making tax assessments?
  • Outcome: advice given
  • Key authorities: IRC § 7508A

Full text (IRS public release)

ID:          CCA_2017092510151943
UILC:        7508.00-00

Number: 201740021
Release Date: 10/6/2017
From:
Sent: Monday, September 25, 2017 10:15:19 AM
To:
Cc:
Bcc:
Subject: RE: Disaster for Huricanes in Florida


Hi --------

Section 7508A would suspend the time for making assessments for the postponement
time that applies to this disaster. There are some examples in the regs under that
section. I’ve cc’d ----------------who is much more knowledgeable on disaster relief than I
am.

Thanks-
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