Information Returns

ID:
UILC:
CCA_2013120910424107
6501.04-03
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201402013
Release Date: 1/10/2014
From:
Sent: Monday, December 09, 2013 10:42:42 AM
To:
Cc:
Bcc:
Subject: RE: Request for case assignment - OVDP case -- ---
---concurs with you that the statutes of limitation on assessment of the income tax for tax years ---, and the resulting penalties for failing to file the Forms 3520-A and 5471 for those years remains open until ---as a result of the application of section 6501(c)(8) and as further extended by the timely executed Forms 872 extending the period of limitations on both the income tax and penalties until ---.