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Office of Chief Counsel Internal Revenue Service …

Office of Chief Counsel Internal Revenue Service Memorandum Number: 201052003. Release Date: 12/30/2010. CC:PA: BMPettoni [Third Party Communication: POSTF-123168-10 Date of Communication: <Month> DD, YYYY]. UILC: , , , , date: August 24, 2010. to: Mortensen , Associate Area Counsel (Small Business/Self-Employed), Salt Lake City from: Charles A. Hall Senior Technician Reviewer (Procedure & Administration). subject: ---------------------------------- ---------------------------------------- ------------------- This Chief Counsel Advice responds to your request for assistance. This advice may not be used or cited as precedent. LEGEND. Taxpayer = ------------------- Tax Year = ---------------------------------------- ------ Date 1 = ----------------------- Date 2 = ----------------------- Date 3 = ----------------------- Date 4 = ----------------------- Date 5 = ----------------------- Date 6 = ----------------------- Date 7 = ----------------------- Amo

POSTF-123168-10 2 ISSUES 1. Whether section 7502 of the Code applies to an amended return that is mailed on the day the statute of limitations for assessment expires but is received after that

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