Keeping CPAs Up to Date on Tax Matters

A site devoted to articles on current developments in federal taxes geared toward CPAs in tax practice.

Lack of Regulations Does Not Allow IRS to Refuse to Consider Application for Extended Replacement Period Where Statute is Self-Executing

September 16, 2015 by Ed Zollars, CPA

If the tax law provides for an application for special treatment to be made in such time and manner as the IRS may require, can a taxpayer make the application if the IRS hasn’t gotten around to writing any regulations or provided other guidance on the subject? This was the issue addressed by Chief Counsel Memorandum 201537021.