Menu
Tax Notes logo
HOMETax Notes ResearchFederalIRS Private Rulings And Advicee mail chief counsel advice

Mitigation Provisions Supersede TEFRA Provisions for Administrative Adjustment Request Purposes

AUG. 20, 2009

ECC 200944037

DATED AUG. 20, 2009
DOCUMENT ATTRIBUTES
Citations: ECC 200944037

UILC: 1311.00-00

 

Release Date: 10/30/2009

 

ID: CCA_2009082010555637

 

 

Office: * * *

 

 

From: * * *

 

Sent: Thursday, August 20, 2009 10:56:00 AM

 

To: * * *

 

Cc:

 

Subject: RE: [* * *] TEFRA assessment/statute

 

 

One additional point. The mitigation provisions supersede the TEFRA provisions since section 1311(a) allows an adjustment that otherwise would be prohibited by "operation of any law or rule of law." So if the requirements of mitigation are met, they supersede the requirements of section 6227 and we would be required to issue a refund even if no valid claim was filed.
DOCUMENT ATTRIBUTES
Copy RID