Ezel / IRS Rulings / 200220027

PLR 200220027: Amendment limits earlier ruling on LLC partnership status

Number
200220027
Outcome
Other outcome
Document type
Private Letter Ruling
IRS subject
Definitions
Topics
Entity classification
Code sections
§ 7701
Ruling dated
September 24, 2001
Publicly released
May 17, 2002
Source
View Official PDF

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This page covers one taxpayer's ruling, issued in 2002, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2002
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

The IRS amended an earlier private letter ruling to state that an LLC represented itself as classified as a partnership under Treas. Reg. § 301.7701-3. The amendment also added a limitation: the IRS expressed no opinion on whether the LLC actually was a partnership or whether the ruling recipient was a partner. All other parts of the earlier ruling remained the same. This letter supplies only those changes to the earlier ruling.

Ruling snapshot

  • Question: What does the amendment change about the earlier ruling's discussion of the LLC?
  • Outcome: other, amendment clarifying a representation and reserving the partnership classification questions
  • Key authorities: Treas. Reg. § 301.7701-3

Full text (IRS public release)

DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE 200220027
WASHINGTON, D.C. 20224

TAX EXEMPT AND
GOVERNMENT ENTITIES

DIVISION

Date: September 24, 2001 Contact Person:

ID No.

UIL: 9999.98-00 Telephone Number:

T:EO:B1

Employer Identification Number:

Dear Sir/Madam:
This letter modifies private letter ruling number 200041038 dated July 20, 2000.

The first sentence in the first paragraph under the heading “Rationale” should be deleted and the following sentence should be substituted in its place:

LLC has represented that it is classified as a partnership for federal tax purposes under section 301.7701-3 of the Procedure and Administration Regulations.

In addition, under the heading “Rulings,” the following sentence should be added to the second paragraph following the three numbered rulings:

In particular, no opinion is expressed regarding (i) whether the LLC is classified as a partnership for federal tax purposes, or (ii) if LLC is classified as a partnership, whether you are a partner in the partnership. In all other respects, private letter ruling number 200041038 remains the same. In accordance with the Power of Attorney currently on file with the Internal Revenue Service, we are sending a copy of this letter to your authorized representative.

Sincerely,

(signed) Marvin Friedlander

Marvin Friedlander
Manager, Exempt Organizations
Technical Group 1

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