Assessment or Collection After Limitation Period

ID:
UILC:
CCA_2015111709354958
6401.01-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201550035
Release Date: 12/11/2015
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Sent: Tuesday, November 17, 2015 9:35:49 AM
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Subject: Effect of failure to move payment to credit-elect year
Thanks for bringing this to our attention. Rev. Rul. 85-67 does not apply where a credit elect was not applied to the subsequent year with the unassessed liability until after the
ASED. We plan on clarifying the Statute Handbook (IRM 25.6) in this regard.