IRS CCA: Guidance on Informal Claim for Tax Refund (IRC §7422)

The Chief Counsel’s Office advised on informal claims for refund. The guidance states that a valid informal claim puts the Commissioner on notice that the taxpayer believes an erroneous tax has been assessed and there is belief that the taxpayer is owed a refund. The informal claim must be read in the light of the peculiar circumstances then well known to the Commissioner, and would need to be ascertainable from the taxpayer’s file that a refund has been claimed by any revenue agent tasked to review it. It would not be sufficient that the IRS has information somewhere in its ...