Other Requests

ID: CCA_2009091815414337 Number: 200945059
Release Date: 11/6/2009
Office: ---
UILC: 6227.05-00
From: ---
Sent: Friday, September 18, 2009 3:41:49 PM
To: ---
Cc: ---
Subject: RE: Barred Overassessment?
There is no agreement for a refund if we did not cosign the agreement. The agreement signed by only one party would also not likely constitute a valid AAR under Samuelli v. Commissioner. Under that precedent there is no informal claim doctrine as there is for non-TEFRA refunds. So taxpayer may not be entitled a refund. As a consequence, the mitigation issue appears moot.
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