Dont have to worry

CCA 201119033




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UIL No. 6532.02-06



Headnote:



Reference(s):



FULL TEXT:

ID: CCA-203944-11



Office: [Redacted Text]



UILC: 6532.02-06



Number: 201119033



Release Date: 5/13/2011



From: [Redacted Text]



Sent: Thursday, February 3, 2011 9:44 AM



To: [Redacted Text]



Cc: [Redacted Text]



Subject: RE: Question



Hi,[Redacted Text]



There is no “don't have to worry” period for the taxpayer when Appeals is still working the case on the eve of the 2-year statute expiration date. Taxpayers can protect themselves only by filing suit or executing an extension. In this type of situation when the Service is considering allowing a portion of the claim, the Service should consider extending the period for filing suit on a Form 907 as authorized in section 6532(a)(2).