Claim for refund of federal telephone excise tax not allowed

Refund of federal telephone excise tax not allowed

The IRS today publicly released a redacted field advice memorandum* that concludes that a corporate taxpayer may not supplement a timely filed claim for refund of the federal telephone excise tax after the section 6511(a) limitations period has expired to include a claim for a refund of taxes paid by other entities that the taxpayer acquired and that were not included in the original refund claim. 20151703F (dated January 26, 2015)

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The analysis provided in the field advice memo [PDF 275 KB] distinguishes between situations when supplemental claims for refund are considered an amendment to the original timely claim, and not an untimely new claim.

*Field advice memo documents are prepared by IRS field attorneys in the Office of Chief Counsel, are reviewed by an Associate Office, and are subsequently issued to IRS field or service center employees. The memo cannot be used or cited as precedent.

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