Other Requests

ID:
UILC:
CCA_2014021115284101
6227.05-00, 6227.05-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201416008
Release Date: 4/18/2014
From:
Sent: Tuesday, February 11, 2014 3:28:41 PM
To:
Cc:
Bcc:
Subject: RE: AAR Question - Refund Statute
One clarification. The extension in the second sentence below would extend the period for partnerlevel AAR’s which would, if filed during that period, extend the period for issuing a refund based on that partner-level AAR for 2 years from the date of the partner AAR.
The reference in the first sentence to Form 9247 was meant to be to Form 9248.
____
From:
Sent: Tuesday, February 11, 2014 2:33:33 PM
To:
Cc:
Subject: RE: AAR Question - Refund Statute
The period for issuing refunds will expire 2 years after the TMP AAR or longer if he signs a Form 9247. It does not appear that an extension on Form 9248 to ---would do anything other than extend the 2 year period by one day.
If the TMP signed a Form 872-P before the normal section 6229(a) period, this would extend the refund period to the agreed date plus 6 months. I.R.C. 6227(b)(2).
Any partner level AAR would extend the refund statute for that partner for 2 years from the date of the partner-level AAR.