Restrictions on Examination of Taxpayer

ID: CCA_2009093014322054 Number: 200946038
Release Date: 11/13/2009
Office: ---
UILC: 7605.01-00
From: ---
Sent: Wednesday, September 30, 2009 2:32:23 PM
To: ---
Cc: ---
Subject: RE: Examination Reopening Procedures
You have stated that, while there will be adjustments to tax years --- or ---, the closed years, those adjustments will not result in adjustments to the taxpayer's liability for tax years --- or ---. The adjustments to tax years --- or --- do not, then, involve a "reopening" as defined by Rev. Proc. 2005-32 section 4.02.
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