Rev. Rul. 69-543

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Revenue Ruling 69-543

Overview

Assessment and collection of deficiencies resulting from the disallowance of investment credit carryovers can be made even though the year in which the investment credit was incorrectly claimed is barred by section 6501(a) of the Code.

Rev. Rul. 69-543, 1969-2 C.B. 1, holds that assessment and collection of deficiencies resulting from the disal lowance of investment credit carry overs can be made even though assess ment for the year in which the invest ment credit was incorrectly claimed is barred by section 6501(a) of the Code. See Mennuto v. Commissioner , 56 T.C. 910 (1971), acq ., 1973-2 C.B. 2.

source: Rev. Rul. 82-49

Related information, from Rev. Rul. 77-225:

When the Service disallowed deductions claimed in an income tax return on which the period of limitations for assessment of a deficiency had expired for the sole purpose of determining the correct amount of a net operating loss carryover to a statutorily open year under examination, the disallowance was held to be proper for the purpose of determining the net operating loss carryover to such year. See Phoenix Coal Company, Inc. v. Commissioner , 231 F.2d 420 (2d Cir. 1956). See also Rev. Rul. 56-285, 1956-1 C.B. 134, involving a net operating loss carryover; Rev. Rul. 69-543, 1969-2 C.B. 1, involving investment credit carryovers; and Rev. Rul. 74-61, 1974-1 C.B. 239, involving the correction of taxable income for a base period year for income averaging purposes. The cited Revenue Rulings involve adjustments of income tax items of a taxable year closed by the statute of limitations. In each of those instances, section 6501 of the Code did not preclude making adjustments to a closed year solely to determine the in come tax consequences of a taxable year that was still open under the statute of limitations.