What is the purposes of a Protective Refund Claim?

Protective claims are used when a taxpayer\’s right to a refund is contingent on future events, such as the outcome of litigation, a change in the law, or a pending IRS or court determination. The claim is filed to \”protect\” the taxpayer\’s right to a refund in case the contingency is resolved in their favor after the normal limitations period for filing a claim would have expired. See CCA 200547011, ECC 200848045.