Reconsideration by Secretary

ID:
UILC:
CCA_2015102811112321
6532.02-06
Number: 201549029
Release Date: 12/4/2015
From:
Sent: Wednesday, October 28, 2015 11:11:24 AM
To:
Cc:
Bcc:
Subject: RE: 6514 & 6532
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The law in this area has not changed. No refund can be allowed if the 2-year period under § 6532(a)(1) for filing suit has expired, unless the taxpayer has filed suit within that period or taxpayer and the IRS have executed an Agreement to Extend the Time to Bring Suit (Form 907) within the period of limitation. Reconsideration after the mailing of the notice of disallowance does not extend the 2-year period.
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