IRS CCA On When Statute of Limitations Starts To Run

Jun 28, 2020 0 Replies

On Feb. 6, 2020 the IRS Office of Chief Council published a CCA that provides the IRS interpretation of Code sections 6501 (the period for assessment) and 6511 (how long do we have to file for a refund). The question on the table is which return is used when a taxpayer who has an extension to file, files a tax return during the extension period and subsequently files another return (superceding return) before the extension runs out. Should the IRS use the filing date of the first return or the filing date of the superceding return?



I am not going to give you the answer. Take an educated guess and either read the CCA here:



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Or, read a summary here:



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OR a shortcut at
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