IRS CCA: Look Back Rule Goes to First Extension Where Multiple Extensions Executed (IRC §6511)

The look back provision of I.R.C. §6511(c)(2) applies on multiple extensions by reaching back to the first extension, the Chief Counsel’s Office informally advised. If an agreement to extend the period of assessment is reached under §6501(c)(4) , then §6511(c)(1) provides the taxpayer’s time to file a claim for refund is extended to six months after the agreed upon assessment period ends, the Chief Counsel’s Office stated. The §6511(c)(2) look back provision then limits the amount the taxpayer can claim in a refund to (1) payments made between the time the agreement was executed and the ...